LEGAL

1. About EnvoyX

EnvoyX is a technology company building credit infrastructure that supports lending operations for businesses across Africa. We are not a bank and do not carry out direct lending activities. All credit and lending facilities are provided by licensed banks, microfinance institutions, and regulated lenders on our platform.

We connect businesses seeking capital with verified lenders, help operators and platforms embed financial products for their merchants, and support corporates in managing their accounts payable. In doing so, we collect and process personal and business data to operate our services effectively and responsibly.

2. Information We Collect

We collect information in the following ways:

a. Information you provide directly

• •Business registration details (company name, registration number, tax identification)
• •Identity documents for KYB and KYC verification (government-issued ID, director information)
• •Contact information (name, email address, phone number)
• •Financial information (bank account details, invoice records, transaction history)
• •Documents uploaded for credit assessment (bank statements, financial records)
• •Correspondence with EnvoyX support

b. Information collected automatically

• •Device and access data (IP address, device type, browser information)
• •Usage data (pages visited, session duration, activity logs)
• •Transaction data generated through platform activity
• •Geolocation data where relevant and permitted

c. Information from third parties

• •Credit bureau data and financial verification providers
• •Partner platforms and operators who refer businesses to our platform
• •Regulatory and compliance databases

3. How We Use Your Information

We use the information we collect to:

• •Verify your identity and eligibility to access our platform and services
• •Assess creditworthiness and facilitate financing decisions by licensed lenders on our platform
• •Process transactions and communicate updates to relevant parties
• •Manage risk, detect fraud, and prevent unauthorised or illegal activity
• •Improve and develop our products and services
• •Comply with legal, regulatory, and compliance obligations
• •Respond to inquiries and provide customer support
• •Send relevant service updates, notifications, and product information

4. How We Share Your Information

We do not sell your personal data. We share your information only in the following circumstances:

a. With licensed lenders and financial partners

To facilitate credit assessment and financing decisions, relevant business and financial data is shared with licensed banks, microfinance institutions, and regulated lenders on our platform. This sharing is necessary for the delivery of our services.

b. With operators and platform partners

Where you access EnvoyX services through an operator or platform that has integrated our infrastructure, we may share relevant data with that partner to deliver the service you are using.

c. With service providers

We work with third-party service providers for functions including identity verification, credit bureau checks, cloud infrastructure, analytics, and customer support. These providers are bound by confidentiality obligations and may only use your data for the specific purposes we engage them for.

d. For legal and regulatory compliance

We may disclose your information where required by law, court order, or regulatory authority, including obligations under applicable AML, CFT, and financial services regulations in the jurisdictions where we operate.

e. In connection with a business transaction

In the event of a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction. We will notify affected users where required by law.

5. Consent

By registering for or using EnvoyX services, you consent to the collection, use, and processing of your information as described in this Policy. Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time by contacting us at the details provided below.

Withdrawal of consent may affect your ability to continue using certain features of our platform.

6. Data Retention

We retain your information for as long as your account is active, as needed to deliver our services, or as required by applicable legal and regulatory obligations. Even after account closure, we may retain certain data to comply with anti-money laundering laws, tax obligations, dispute resolution requirements, and other statutory obligations applicable in the jurisdictions where we operate.

7. Security

Security is designed into every product we build. We implement technical and organisational measures to protect your personal and business data against unauthorised access, disclosure, loss, or destruction. These include encryption of data in transit and at rest, strict access controls, and regular security reviews.

We are actively working toward formal certification under the Nigerian Data Protection Act (NDPC), the Commission Nationale de l'Informatique et des Libertés (CNIL) in Côte d'Ivoire, and the General Data Protection Regulation (GDPR) standards. Until formal certification is obtained, we operate to these standards as our benchmark.

No system is entirely immune to risk. If you believe your account security has been compromised, contact us immediately at privacy@envoyx.com.

8. International Data Transfers

EnvoyX does not transfer your personal or business data across jurisdictions. Data collected in a given country is stored and processed within that same jurisdiction in accordance with applicable local data protection laws.

Where we engage third-party service providers, we require that they process data only within the jurisdiction in which it was collected, subject to the same legal and compliance standards that apply to us.

9. Cookies

We use cookies and similar technologies to authenticate users, maintain session security, understand how our platform is used, and improve your experience. You may manage your cookie preferences through your browser settings. Disabling certain cookies may limit the functionality of our platform.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

• •Access the personal data we hold about you
• •Request correction of inaccurate or incomplete data
• •Request deletion of your data, subject to legal and regulatory obligations
• •Object to or restrict certain types of data processing
• •Withdraw consent where processing is based on consent
• •Lodge a complaint with the relevant data protection authority in your jurisdiction

To exercise any of these rights, contact us at privacy@envoyx.com. We will respond within the timeframe required by applicable law.

11. Account Deletion

You may request deletion of your account by sending an email to support@envoyx.com. We will process your request and confirm once completed. Account deletion will result in the removal of your profile and associated data, subject to our obligation to retain certain records for legal and regulatory compliance purposes.

We reserve the right to decline account deletion requests where there are pending transactions, active disputes, or outstanding obligations on the account.

12. Age Restriction

Our platform and services are intended for businesses and individuals aged 18 and above. We do not knowingly collect data from persons under 18. If you believe a minor has submitted information to us, please contact us immediately.

13. Links to Third-Party Sites

Our platform may contain links to third-party websites. EnvoyX is not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party sites you visit.

14. Updates to This Policy

We may update this Policy as our services evolve or as required by applicable law. We will notify users of material changes by posting the revised Policy on our website with an updated effective date. Continued use of our platform after changes are posted constitutes acceptance of the revised Policy.

15. Governing Law

This Policy is governed by and interpreted in accordance with the laws of the Federal Republic of Nigeria and, where applicable, the laws of the Republic of Côte d'Ivoire and relevant WAEMU/BCEAO regulations. Disputes arising under this Policy shall be subject to the jurisdiction of the courts of the applicable territory.

16. Contact Us

For questions, requests, or concerns about this Policy or how we handle your data, contact us at:

Email: privacy@envoyx.com

We take all privacy inquiries seriously and will respond promptly.