This notice explains what personal information we collect when you use Flippr, why we collect it, who we share it with, and the rights you have. We handle personal data in line with the Nigeria Data Protection Act 2023.
Operator: Engagoor Limited (RC 9520908)
Registered address: 39C, Road 27, Ikota Villa Estate, Ikota, Lagos State, Nigeria
Contact: hello@engagoor.xyz
1. Who controls your data
Engagoor Limited is the data controller for the personal information described here. You can reach us about any privacy matter at hello@engagoor.xyz.
2. What we collect
Information you give us
- Identity details: full name, date of birth, residential address, and government identifiers such as your BVN or NIN.
- Identity documents and images: a photo of your government-issued ID and a selfie or short video used to confirm you are the person on the document.
- Contact details: email address and phone number.
- Bank details: account number, bank name and account name used for payouts.
- Anything else you send us, such as the content of support messages.
Information we generate or receive
- Transaction records: amounts, assets, wallet addresses, rates, fees, timestamps and status.
- Verification results received from our identity verification providers.
- Technical data: device type, operating system, app version, IP address and log data.
- Screening results from sanctions, politically exposed person and adverse media checks.
3. Why we use it and our legal basis
- To provide the service. Creating your account, processing conversions and paying you. Basis: performance of our contract with you.
- To meet legal obligations. Identity verification, sanctions screening, transaction monitoring, record keeping and reporting to authorities. Basis: compliance with a legal obligation.
- To prevent fraud and abuse. Detecting suspicious activity and protecting our systems and other users. Basis: our legitimate interests.
- To support and improve the service. Answering your questions and fixing problems. Basis: our legitimate interests.
- To send you service messages. Transaction confirmations and important notices. Basis: performance of our contract. Marketing messages, where we send them, are sent with your consent and you can opt out at any time.
4. Who we share it with
We share personal information only where we need to, and only to the extent needed:
- identity verification and screening providers who carry out our checks;
- payment, banking and exchange partners who help settle your payout;
- cloud hosting, storage and infrastructure providers who run our systems;
- professional advisers such as auditors and lawyers, where they are bound by confidentiality; and
- regulators, law enforcement, courts and other authorities where we are required or permitted by law to disclose.
We do not sell your personal information, and we do not rent or trade it for marketing.
5. Transfers outside Nigeria
Some of our providers process data outside Nigeria. Where that happens we take steps required by the Nigeria Data Protection Act 2023 to make sure your information stays protected, including using contractual safeguards with those providers.
6. How long we keep it
We keep identity records, verification results and transaction records for at least five years after our relationship with you ends, because anti money laundering law requires it. Support correspondence and technical logs are kept for shorter periods appropriate to their purpose. When a retention period ends we delete the data or anonymise it.
Deleting your account
You can delete your account yourself, from Settings in the app. When you do, we sign you out everywhere and delete your password, your rate alerts, your notification settings, your phone number and any unused verification codes. Your saved bank accounts stop showing and can no longer be paid to.
We cannot delete your identity check or your transaction history at the same time. The Money Laundering (Prevention and Prohibition) Act 2022 and the Central Bank of Nigeria's AML/CFT Regulations require us to keep those for at least five years after your account closes. The app shows you the exact date they are destroyed. After that date they are deleted automatically, and your withdrawal amounts and dates remain only as anonymous accounting entries with your details removed. If there is an open investigation, court order or regulator request touching your account, we keep the records until it is resolved.
Because your email stays part of that retained record, you cannot sign up again with it while the account is closed. If you want to use Flippr again, email hello@engagoor.xyz.
7. Your rights
Subject to the conditions in the Nigeria Data Protection Act 2023, you may:
- ask for a copy of the personal data we hold about you;
- ask us to correct information that is wrong or incomplete;
- ask us to delete data, where we are not required to keep it;
- object to or ask us to restrict certain processing;
- ask us to transfer your data to another provider where technically feasible; and
- withdraw consent where we relied on consent, without affecting earlier processing.
Some rights are limited. For example we cannot delete identity and transaction records that we are legally required to retain. To exercise a right, email hello@engagoor.xyz. We respond within one month and will tell you if we need longer.
If you are not satisfied with how we handled your request, you can complain to the Nigeria Data Protection Commission.
8. Security
We use encryption in transit, access controls, and restricted internal access to protect your information. Identity documents and verification data are handled by specialist providers under contract. No system is perfectly secure, so we also ask you to protect your own account, keep your device and app updated, and tell us immediately if you think someone else has access.
9. Cookies
Our website uses only the cookies needed to load and display the page. It does not use advertising cookies. If we add analytics in future we will update this notice first.
10. Children
Flippr is not for anyone under 18. We do not knowingly collect data from children. If we learn that we have, we delete it.
11. Changes
If we change this notice we will post the new version here and update the date at the top. If a change materially affects you we will notify you in the app or by email.
12. Contact
Engagoor Limited, 39C, Road 27, Ikota Villa Estate, Ikota, Lagos State, Nigeria. Email hello@engagoor.xyz.