Welcome to PADDYSWAP NIGERIA LIMITED Privacy Policy

This Privacy Policy applies to PADDYSWAP NIGERIA LIMITED (hereinafter referred to as "PADDYSWAP," "we," "us," or "our"). This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of our services which include:

• Bill payments
• Flight ticket payment
• Utility Bills payment (NEPA Bills, Water Bills)
• Educational payments (WAEC, NECO & JAMB Registration payment)
• Hotel Booking payment
• Air BnB bookings
• Purchase/Selling of Gift Cards
• Airtime and data purchase
• Other related technology services

When you use our services, you trust us with your information. We are committed to keeping that trust. This Privacy Policy is designed to help you understand what information we collect, why we collect it, and how you can manage your information.

Data Controller

PADDYSWAP NIGERIA LIMITED, registered with the Corporate Affairs Commission of Nigeria with registration number 7139129, is the data controller responsible for your personal information. Our headquarters are located at ABEKE ROAD, SAPELE, DELTA STATE, with postal code 331107. For any inquiries regarding your personal data, please contact us at contact@paddyswaps.com.

Information We Collect

To provide our services effectively, we collect various types of information, including:

• Account Information: When you create an account, we collect information such as your name, email address, phone number, and billing address.
• Transaction Information: We collect details about transactions you make through our platform, including payment method information, transaction amount, date of transaction, and payment status.
• Service Usage Information: Information about how you use our services, including bill payment history, flight booking details, gift card transactions, and other service usage patterns.
• Device Information: Information about the device you use to access our services, including hardware model, operating system, unique device identifiers, and mobile network information.
• Location Information: We may collect and process information about your precise or approximate location, derived from your IP address or device.
• Communication Information: Records of your communication with PADDYSWAP, including customer support interactions.

Our Purposes and Lawful Basis

We use the information we collect for various purposes, including:

• Providing and Improving Our Services: To process transactions, provide customer support, and enhance user experience.
• Security and Fraud Prevention: To detect, prevent, and address fraud, security threats, and other harmful activities.
• Communication: To communicate with you about your account, transactions, and important service updates.
• Compliance: To comply with legal obligations, including anti-money laundering regulations and know-your-customer requirements.
• Marketing: With your consent, to provide you with information about our services, promotions, and offers that may interest you.

Our lawful basis for processing your personal information includes:

• Contract Performance: Processing necessary for the performance of our contract with you.
• Legitimate Interests: Processing necessary for our legitimate interests, such as fraud prevention and service improvement.
• Legal Obligation: Processing necessary for compliance with our legal obligations.
• Consent: Processing based on your specific consent, such as for marketing communications.

Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

• Encryption of sensitive information
• Regular security assessments and updates
• Strict access controls for our employees and contractors
• Regular staff training on data security practices

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

Disclosure of Data

We may disclose your personal information in the following circumstances:

• Service Providers: We share information with trusted third-party service providers who perform services on our behalf, such as payment processing, fraud prevention, and customer support.
• Business Partners: We may share information with business partners to provide specific services you have requested, such as flight booking providers or utility companies.
• Legal Compliance: We may disclose information if required by law, regulation, legal process, or governmental request.
• Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
• With Your Consent: We may share information with third parties when you have given us your consent to do so.

We require all third parties to respect the security of your personal information and to treat it in accordance with applicable laws.

International Data Transfers

PADDYSWAP operates primarily in Nigeria, but some of our service providers and partners may be located in other countries. As a result, your personal information may be transferred to, stored, and processed in countries outside Nigeria, which may have different data protection laws.

When we transfer your personal information outside Nigeria, we ensure that appropriate safeguards are in place to provide an adequate level of protection for your data, as required by applicable law. These safeguards may include:

• Contractual clauses that impose appropriate data protection obligations on the recipient
• Ensuring the recipient is in a country with adequate data protection laws
• Obtaining your consent for the transfer

Rights of the User

Under applicable data protection laws, you have certain rights regarding your personal information:

• Access: You have the right to request a copy of the personal information we hold about you.
• Rectification: You have the right to request correction of any inaccurate personal information we hold about you.
• Erasure: You have the right to request deletion of your personal information in certain circumstances.
• Restriction: You have the right to request restriction of processing of your personal information in certain circumstances.
• Data Portability: You have the right to receive your personal information in a structured, commonly used format and to transmit that data to another controller.
• Objection: You have the right to object to processing of your personal information in certain circumstances, including for direct marketing purposes.

To exercise any of these rights, please contact us at contact@paddyswaps.com. We will respond to your request within the timeframe specified by applicable law.

Complaint Submission

If you have concerns about how we handle your personal information, please contact us first at contact@paddyswaps.com so that we can try to resolve the issue. If you are not satisfied with our response, you have the right to lodge a complaint with the Nigerian Data Protection Commission or other relevant supervisory authority.

Types of Cookies We Use

Our website uses cookies to enhance your experience and provide certain functionalities. Cookies are small text files stored on your device when you visit our website. We use the following types of cookies:

• Essential Cookies: Necessary for the operation of our website and enabling you to use its features.
• Functional Cookies: Allow our website to remember choices you make and provide enhanced, personalized features.
• Analytical/Performance Cookies: Help us understand how visitors interact with our website by collecting and reporting information anonymously.
• Targeting Cookies: Record your visit to our website, the pages you have visited, and the links you have followed to make our advertising more relevant to your interests.

Purpose of Our Cookies

We use cookies for various purposes, including:

• Keeping you signed in to your account
• Remembering your preferences and settings
• Understanding how you use our website to improve its performance
• Detecting and preventing fraud
• Providing you with relevant advertising

Controlling Your Cookies

You can control and manage cookies in various ways. Most web browsers allow you to manage your cookie preferences. You can:

• Delete cookies from your device
• Block cookies by activating the setting on your browser that allows you to refuse all or some cookies
• Set your browser to notify you when you receive a cookie

Please note that if you choose to block or delete cookies, you may not be able to access certain areas or features of our website, and some services may not function properly.

Updates to Cookie Policy

We may update our Cookie Policy from time to time. We will notify you of any changes by posting the new Cookie Policy on this page and updating the "Last Updated" date at the top of this policy.

General Refund Policy

At PADDYSWAP NIGERIA LIMITED, we strive to ensure customer satisfaction with all our services. This refund policy outlines the conditions under which we process refunds for various services we offer. By using our services, you agree to the terms of this refund policy.

Our general principles regarding refunds are:

• All refund requests must be submitted within 7 days of the transaction date
• Refunds are processed in the original form of payment when possible
• Processing fees may be deducted from refund amounts as specified below
• Proof of transaction is required for all refund requests

Bill Payments Refunds

For utility bill payments (including NEPA Bills, Water Bills) and other bill payment services:

• Failed Transactions: If your payment was processed but the service was not delivered to the intended recipient, we will process a full refund.
• Duplicate Payments: If you accidentally made the same payment twice, we will refund the duplicate payment after confirmation from the service provider.
• Incorrect Payment Details: If you provided incorrect payment details (such as wrong account number), we will attempt to recover the funds. If successful, the refund will be processed minus any recovery charges imposed by the service provider.

Please note that once a bill payment has been successfully processed and delivered to the service provider, refunds are subject to the service provider's policies and may not be possible in all cases.

Flight Ticket Refunds

Refunds for flight tickets are subject to the airline's refund and cancellation policies. PADDYSWAP serves as a payment processor for these transactions and follows these guidelines:

• Airline Cancellations: If the airline cancels your flight, we will process a refund as per the airline's refund policy.
• Customer Cancellations: If you cancel your booking, refund eligibility and amounts are determined by the airline's cancellation policy. Cancellation fees may apply.
• Failed Bookings: If your payment was processed but the ticket was not issued, we will process a full refund.

Our service fee for flight ticket bookings is non-refundable once the ticket has been issued. For flight ticket refunds, processing time may be extended due to airline processing times.

Gift Card Transactions

For purchase and sale of gift cards:

• Purchase of Gift Cards: Once a gift card has been delivered to you, it cannot be returned or refunded due to the digital nature of the product.
• Sale of Gift Cards: If we are unable to verify or process a gift card you have sold to us, we will return the gift card to you.
• Rate Changes: If there is a significant rate change between the time of transaction agreement and processing, you may request to cancel the transaction before it is completed.

We verify all gift cards before completing transactions. If a gift card is found to be invalid, fraudulent, or reported stolen, we reserve the right to refuse the transaction and will not process payment.

Airtime & Data Refunds

For airtime and data purchase services:

• Wrong Number: If you accidentally sent airtime or data to the wrong number, we cannot guarantee a refund as these services are typically delivered instantly.
• Failed Transactions: If your payment was processed but the airtime or data was not delivered, we will process a full refund or re-attempt the service delivery, at your preference.
• Network Issues: If the service was not delivered due to network operator issues, we will coordinate with the operator to resolve the issue or process a refund.

Please note that network operators may have specific policies regarding reversal of airtime or data transfers which are beyond our control.

Refund Process

To request a refund, please follow these steps:

1. Log in to your PADDYSWAP account
2. Navigate to the transaction history section
3. Select the transaction for which you're requesting a refund
4. Click on "Request Refund" and complete the form with all required information
5. Submit the necessary documentation to support your refund request

Alternatively, you can contact our customer support at contact@paddyswaps.com with your refund request, including your transaction reference number and reason for the refund.

Refund Timeline

Once your refund request has been approved:

• Bank Accounts: Refunds to Nigerian bank accounts are typically processed within 3-5 business days.
• Wallet Balance: Refunds to your PADDYSWAP wallet balance are typically processed within 24 hours.
• Credit/Debit Cards: Refunds to cards may take 5-15 business days, depending on your card issuer's policies.

Please note that processing times may be extended during peak periods or for international transactions.

Contact for Refunds

If you have any questions about our refund policy or need assistance with a refund request, please contact our customer support team:

• Email: contact@paddyswaps.com
• Phone: 07067077526
• Address: ABEKE ROAD, SAPELE, DELTA STATE, 331107

Our customer support team is available Monday through Friday, 9:00 AM to 5:00 PM WAT.

Policy Updates

We may update these policies from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated policies on our website or through other communication channels. Your continued use of our services after such modifications constitutes your acknowledgment of the modified policies and your agreement to abide and be bound by them.

Last updated: May 14, 2025