Privacy Policy

1. Scope & Eligibility

This Policy applies when you access or use our Services. By using the Services, you agree to the practices described here. If you do not agree, please do not use the Services.

Minimum age: 18+

2. Information We Collect

2.1 Information you provide to us

• Account details (e.g., name, email, phone number, username). Passwords are stored using industry‑standard hashing.
• Identity & verification data for KYC/AML compliance (e.g., government ID, selfie, proof of address, date of birth) where required by law.
• Financial & transaction data (e.g., bank account details you provide for withdrawals, wallet addresses, transaction history, exchange orders, balances, payout records).
• Communications (e.g., support messages, emails, in‑app messages) and your preferences (e.g., newsletter opt‑in).
• Marketing content and survey responses you choose to share.

2.2 Information collected automatically

• Usage & device data such as IP address, device/browser type, settings, pages viewed, referring/exit pages, and timestamps.
• Cookies and similar technologies (see Section 6).
• Approximate location inferred from your IP address to help detect fraud and present relevant options (e.g., currency).

2.3 Information from third parties

• Verification & compliance partners (identity verification, sanctions screening, fraud prevention) consistent with law.
• Payment and banking partners who help process deposits, withdrawals, and settlements.

3. How We Use Information

• Provide, operate, and improve the Services, including orders, wallets, payments, and customer support.
• Verify identity, manage risk, detect and prevent fraud and abuse, and comply with AML/CFT obligations.
• Communicate with you about transactions, security, changes to terms, and important updates.
• Send marketing communications with your consent and honor your opt‑out choices.
• Personalize content and measure performance of our Services.
• Maintain business records, accounting, auditing, and regulatory reporting.

4. Legal Bases (Nigeria NDPA 2023)

We process personal data under the Nigeria Data Protection Act (NDPA) 2023 and other applicable laws based on:

• Contract – to create and manage your account and deliver the Services you request.
• Legal obligation – to comply with AML/CFT, tax, and regulatory requirements (e.g., identity verification, record‑keeping).
• Legitimate interests – to secure our Services; prevent fraud; improve features; and protect our users and business (balanced against your rights).
• Consent – for certain optional uses (e.g., marketing emails, certain cookies). You may withdraw consent at any time.

5. Sharing & Disclosure

We do not sell personal data. We may share information with:

• Service providers under contract who support our operations (hosting, security, analytics, email/SMS delivery, customer support, identity verification, payment and banking facilitation). They may only use data as instructed by MiloSwap and must protect it.
• Financial institutions and payment partners to process deposits, withdrawals, settlements, and chargebacks.
• Professional advisers (lawyers, auditors, accountants) under confidentiality duties.
• Authorities and regulators where required by law or to protect rights, users, or public safety.
• Business transfers in connection with a merger, acquisition, financing, or sale of assets. We will continue to protect your data consistent with this Policy.

6. Cookies & Similar Technologies

We use cookies and similar technologies to operate the site, keep you signed in, remember preferences, and measure performance. You can manage cookies through your browser settings. Disabling certain cookies may limit functionality.

• Strictly necessary (authentication, security, load balancing)
• Preferences (remember choices)
• Analytics (understand usage and improve the Services)
• Marketing (with your consent where required)

7. Data Retention

We retain personal data only as long as necessary for the purposes described here, including to provide the Services, comply with legal and regulatory obligations (for example, AML/CFT record‑keeping), resolve disputes, and enforce agreements. Retention periods vary by data category and applicable law.

8. Security

We implement appropriate technical and organizational measures to protect personal data, including encryption in transit, access controls, secure development practices, monitoring, and multi‑factor authentication options. No method of transmission or storage is 100% secure; you also play a role by keeping your credentials safe.

9. Your Rights

Subject to applicable law, you may have the right to:

• Request access to the personal data we hold about you;
• Request correction of inaccurate or incomplete data;
• Request deletion of data in certain circumstances;
• Object to or request restriction of processing in certain cases;
• Request data portability;
• Withdraw consent where processing is based on consent.

To exercise your rights, contact us (see Section 13). We may ask you to verify your identity. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

10. International Transfers

We may process and store information in countries outside Nigeria. Where applicable, we implement safeguards to protect your data, such as contractual data protection clauses with our service providers and other measures required by law.

11. Children

Our Services are intended for adults (18+). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take appropriate steps to delete such information.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes to our practices, technologies, or legal requirements. We will post the updated Policy and revise the "Effective date" above. Where required by law, we will notify you and/or obtain your consent for material changes.

13. Contact Us

If you have questions about this Policy or our data practices, please contact us:

• MiloSwap Giftcard and Crypto Exchange
• Address: 53c Warri, Delta State, Nigeria
• Phone: +234704 905 2351
• Email: info@miloswap.com