Privacy Policy

1. Introduction

Klarity ("we," "our," or "us") is committed to protecting the privacy and security of personal data processed through our KYC/AML compliance platform ("Platform").

2. Legal Basis for Processing

We process personal data in accordance with:

• Nigeria Data Protection Regulation (NDPR);
• Money Laundering (Prohibition) Act and Terrorism (Prevention) Act;
• Guidance from the Central Bank of Nigeria (CBN) and the Nigerian Financial Intelligence Unit (NFIU);
• Applicable international data protection laws, such as the General Data Protection Regulation (GDPR), where relevant.

3. Data We Collect

Depending on the Services used, we may collect and process:

• Identity Information: Name, date of birth, gender, nationality, ID/passport details, facial images, biometric data (if required).
• Contact Information: Email address, phone number, residential address.
• Financial/Transactional Information: Bank account details, payment data, transaction history, source of funds.
• Device/Usage Information: IP address, browser type, device identifiers, log files, geolocation (where necessary for fraud prevention).
• Sanctions & Screening Data: Matches against watchlists, politically exposed persons (PEP) lists, sanctions databases, and adverse media.

4. Purpose of Processing

We process personal data for the following purposes:

• Identity Verification: To confirm the authenticity of users' identities.
• AML/CFT/Anti-PF Compliance: To support Customers in meeting their regulatory obligations.
• Transaction Monitoring: To detect suspicious or unusual financial activities.
• Fraud Prevention & Security: To prevent abuse of the Platform and protect against financial crime.
• Legal Obligations: To comply with requests from regulators, law enforcement, or applicable laws.
• Service Improvement: To enhance and develop our Platform.

5. Customer Responsibility

Customers submitting personal data to the Platform must ensure that they have obtained the necessary legal basis and consent (where required) to share such data with us.

Klarity acts as a data processor (or sub-processor) on behalf of the Customer. Customers remain the data controllers for end-user personal data.

6. Data Sharing & Transfers

We may share personal data with:

• Third-Party Service Providers: For identity checks, sanctions screening, and fraud detection.
• Regulators or Law Enforcement: Where required by law.
• Affiliates & Partners: For delivery of Services under strict contractual safeguards.
• International Transfers: Where data is transferred outside Nigeria, we ensure adequate safeguards are in place, such as standard contractual clauses (SCCs) or equivalent legal mechanisms.

7. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes described above or as required by law.

Identity and compliance records may be retained for up to 5–7 years, in line with AML/CFT regulations.

Once no longer required, data will be securely deleted or anonymized.

8. Security Measures

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

• Encryption and secure transmission protocols (TLS/SSL).
• Role-based access controls.
• Data minimization and pseudonymization where possible.
• Regular security audits and monitoring.

9. Your Rights

Under NDPR (and GDPR, where applicable), you may have the following rights:

• Right to access personal data we hold about you.
• Right to request correction of inaccurate data.
• Right to request deletion (subject to legal/regulatory requirements).
• Right to object to certain processing activities.
• Right to data portability (where applicable).
• Right to withdraw consent (where consent is the lawful basis).

Requests to exercise these rights may be sent to: tech@numore.co

10. Children's Data

Our Services are not directed to children under 18. We do not knowingly process data of minors without verifiable parental consent.

11. Changes to this Policy

We may update this Privacy Policy periodically. Any changes will be posted on our website and become effective upon posting.

12. Contact Information

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