Privacy Policy
Last updated: Mar 17, 2025
Introduction
AlephNull ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy ("Policy") explains how we collect, use, disclose, and safeguard your information when you use the AlephNull platform (the "Platform") and associated services (the "Services"). By accessing or using the Platform, you consent to the practices described in this Policy.
AlephNull is a digital asset custodial platform that serves both financial institutions and retail customers. We are committed to ensuring the privacy and security of your personal information. This Policy outlines the types of personal data we collect, how we use it, and how we protect it, in compliance with applicable data protection laws, including the Nigeria Data Protection Regulation (NDPR).
Whether you are a financial institution or a retail customer, we value your privacy and strive to protect your data at all stages of interaction with the Platform.
Information We Collect
We collect several types of information when you use the Platform, including:
A. Personal Information
We may collect the following personal information, depending on whether you are a financial institution or a retail customer:
• For Financial Institutions:
- Institutional Information: Name of the financial institution, contact details, registration number, and regulatory credentials.
- User Contact Information: Name, email address, phone number, and position of individuals representing the institution.
- Authentication Information: Login credentials, security questions, and other identifiers used to secure your account.
• For Retail Customers:
- Personal Information: Full name, email address, phone number, date of birth, and other data necessary to verify your identity.
- Authentication Information: Login credentials, password, and other account verification data.
- Transaction Information: Data about your digital asset transactions, including asset types, amounts, and dates.
B. Usage Data
We may automatically collect certain information when you interact with the Platform, including:
- Log Data: IP address, browser type, device information, and usage statistics.
- Cookies and Tracking Technologies: Cookies, pixels, and other tracking technologies that collect data about how you interact with the Platform.
C. Transaction Data
In connection with the digital asset custodial services, we collect data about the transactions you process, such as asset information, dates, amounts, and compliance-related data.
How We Use Your Information
We use the information we collect for the following purposes:
A. Providing Services
- For Financial Institutions:: To facilitate the secure custody, management, and storage of digital assets on behalf of your institution.
- For Retail Customers:: To manage your account, process transactions, and ensure the security of your digital assets.
B. Improving the Platform
We use your data to analyze how you interact with the Platform, improve its functionality, and enhance user experience.
C. Compliance with Legal Obligations
We process personal data to comply with applicable laws, including Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations. This may involve sharing data with regulatory authorities as required by law.
D. Communication
We may use your personal information to send important communications about your account, provide customer support, or inform you of updates or changes to the Platform.
E. Marketing and Promotions
With your consent, we may use your contact information to send you information about AlephNull’s products, services, and updates. You can opt out of receiving marketing communications at any time.
Data Sharing and Third Parties
We may share your personal information in the following circumstances:
- With Service Providers:: We may engage third-party service providers who assist us in providing the Platform’s functionality, such as cloud storage, data analytics, and security services. These third parties are obligated to protect your data and use it only for the purposes specified by us.
- For Legal Compliance:: We may disclose your personal information if required to do so by law, including to comply with regulatory requirements, respond to legal requests, or protect the rights, property, and safety of AlephNull, our users, or others.
- Business Transfers: : In the event of a merger, acquisition, or sale of all or part of AlephNull, your personal information may be transferred as part of that transaction.
Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce agreements. The retention period may vary depending on the type of data and the legal requirements.
Your Rights and Choices
As a user, whether you are a financial institution or a retail customer, you have certain rights regarding your personal data:
- Access and Correction:: You may request access to the personal information we hold about you and request corrections if the information is inaccurate or incomplete.
- Data Deletion: : You may request the deletion of your personal data, subject to certain legal exceptions, such as compliance with AML or CFT regulations.
- Opting Out of Marketing Communications: : You can opt out of receiving promotional or marketing emails from us by following the unsubscribe instructions in the email or by contacting us directly.
To exercise any of these rights, please contact us using the details provided at the end of this Policy.
Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include encryption, secure data storage, and regular security assessments. However, please be aware that no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
Changes to the Privacy Policy
AlephNull reserves the right to update or modify this Privacy Policy at any time. If we make material changes, we will notify you via email or a prominent notice on the Platform. Continued use of the Platform after such changes will indicate your acceptance of the updated Privacy Policy.
Contact Information
If you have any questions or concerns about this Privacy Policy or would like to exercise your rights regarding your personal data, please contact us:
- Email: [Insert Contact Email]
- Phone: [Insert Contact Phone Number]
- Address: [Insert Physical Address]
By using the AlephNull Platform, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and processing of your personal information as outlined above.
