Privacy Policy

Prime Heritage Community ("we," "us," or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect information about you when you use our cooperative savings platform ("the Platform"). By using the Platform, you consent to the data practices described in this policy. We encourage you to read this Privacy Policy carefully and contact us if you have questions.

We collect the following categories of personal information: Personal Identification Data: • Full legal name (first name, last name, other names) • Date of birth • Phone number • Email address • Residential address • Profile photograph Government-Issued Identification: • Bank Verification Number (BVN) • National Identification Number (NIN) • Government-issued photo ID (National ID, International Passport, or Driver's License) • Liveness verification data Financial Information: • Bank account details (account number, bank name) • Transaction history on the Platform • Wallet balance and funding records • Subscription and payment records Technical Data: • IP address • Browser type and version • Device information • Usage patterns and session data

We process your personal data for the following purposes: • Account creation and management — To register and verify your identity per our KYC requirements • Service delivery — To manage your savings subscriptions, process contributions, calculate returns, and execute payouts • Security — To detect fraud, prevent unauthorized access, and maintain the integrity of the Platform • Communication — To send payment reminders, account notifications, subscription updates, and support responses • Legal compliance — To meet regulatory requirements, respond to legal requests, and maintain audit records • Platform improvement — To analyze usage patterns and improve our services (anonymized and aggregated data only)

We take the security of your data extremely seriously. All sensitive information is protected using the following measures: • Encryption at rest: BVN, NIN, and bank account numbers are encrypted using 256-bit Fernet symmetric encryption before storage • Encrypted document storage: Government-issued IDs and verification documents are stored in private, encrypted cloud storage (Cloudflare R2) accessible only to authorized administrators • Database security: Our PostgreSQL database is hosted on secure infrastructure with restricted network access • No raw sensitive data: Encrypted fields are never stored or logged in plain text We retain your personal data only for as long as necessary to provide our services and comply with legal obligations. Upon account deletion, your data is securely destroyed within 90 days, except where retention is required by law.

We do not sell your personal data to third parties. We may share limited data with the following trusted partners: • Platnova — Our payment processing partner, for processing wallet funding, contributions, and payouts. Platnova receives only the minimum information required to process transactions. • Cloudflare — For web application security (WAF), DDoS protection, and CDN services. Cloudflare may process your IP address and request headers. • Email/SMS providers — For sending transactional notifications (payment reminders, account alerts). Only your email address or phone number is shared. All third-party partners are contractually obligated to protect your data in accordance with applicable privacy laws.

We use essential cookies to maintain your authenticated session and platform functionality. We do not use advertising or third-party tracking cookies. • Session cookies — Required for maintaining your login state • Security cookies — Used by Cloudflare for bot detection and Turnstile CAPTCHA verification • Preference cookies — To remember your language and display settings You may disable cookies in your browser settings, but this may affect your ability to use certain features of the Platform.

Under the Nigeria Data Protection Regulation (NDPR) and applicable laws, you have the following rights: • Right of access — You may request a copy of all personal data we hold about you • Right to rectification — You may request correction of inaccurate personal data • Right to deletion — You may request deletion of your account and associated data, subject to legal retention requirements • Right to restrict processing — You may request that we limit how we use your data • Right to data portability — You may request your data in a structured, machine-readable format • Right to object — You may object to specific processing activities To exercise any of these rights, please contact us at privacy@primeheritagecommunity.com. We will respond within 30 days.

Prime Heritage Community is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a person under 18, we will take steps to delete that information promptly.

In the event of a data breach that could pose a risk to your rights and freedoms, we will: • Notify affected users within 72 hours of becoming aware of the breach • Report the incident to relevant regulatory authorities as required • Provide details of the nature of the breach, data affected, and mitigation steps taken • Take all necessary corrective actions to prevent recurrence Our admin audit trail system logs all data access events, providing complete accountability and traceability.

We may update this Privacy Policy from time to time. When we do, we will: • Update the "Last Updated" date at the top of this page • Notify registered users via email and in-app notification • Provide a summary of material changes Your continued use of the Platform after changes are posted constitutes your acceptance of the updated Privacy Policy.

If you have questions about this Privacy Policy, your personal data, or wish to exercise your data rights, please contact us: • Email: privacy@primeheritagecommunity.com • General support: support@primeheritagecommunity.com • Address: No63 Brown street(junction) off church street Oshodi Lagos, Nigeria