Privacy Policy

1. Introduction

At Koolboks, we respect your privacy and are committed to protecting your personal data in accordance with the Nigeria Data Protection Regulation (NDPR), the Nigeria Data Protection Act (NDPA), and other applicable laws and regulations.

This Privacy Policy explains how we collect, use, disclose, store, and protect your personal data when you interact with our products, services, website, mobile applications, Pay-As-You-Go (PAYG) solutions, and credit-related services.

2. Scope

This Privacy Policy applies to:

• Website visitors
• Customers and prospective customers
• PAYG and credit users
• Mobile and web application users
• Business partners or service providers interacting with Koolboks

3. Personal Data We Collect

• Identity and Contact Data: Full name, phone number, email address, residential or delivery address, and identification details where required.
• Financial and Credit Data: Payment history, bank or mobile payment information, credit assessment information, and PAYG repayment records.
• Technical and Usage Data: Device information, IP address, browser type, operating system, website and application usage analytics, system logs, and performance data.

4. Legal Basis for Processing

We process personal data based on your consent, performance of a contract, compliance with legal obligations, legitimate business interests, and fraud prevention or security purposes.

5. How We Use Your Data

Your personal data may be used for:

• Product and service delivery
• PAYG account management
• Credit assessment and repayment monitoring
• Customer support and communication
• Regulatory compliance
• Fraud detection and prevention
• Service improvement and analytics
• Marketing or promotional communications where permitted

6. PAYG & Credit-Specific Processing

For PAYG and credit services, we may process device usage information, payment and repayment activity, and account performance data.

Koolboks does not access or monitor personal content stored on your device, including personal files, messages, photos, or unrelated application data.

7. Data Sharing and Disclosure

We may share personal data with:

• Payment processors
• Credit and financing partners
• Logistics and delivery partners
• Regulatory authorities and law enforcement agencies where legally required
• Professional advisers or service providers supporting our operations

8. International Transfers

Where personal data is transferred outside Nigeria, such transfers will be carried out using appropriate safeguards and in compliance with NDPR and applicable data protection requirements.

9. Cookies and Tracking Technologies

Our website and applications may use cookies and similar technologies to:

• Enable website functionality
• Improve user experience
• Analyse website traffic and performance
• Support security and fraud prevention

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy and comply with legal, regulatory, tax, accounting, or reporting obligations.

11. Your Rights

Subject to applicable laws, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request deletion of your data
• Object to certain processing activities
• Withdraw consent where processing is based on consent
• Lodge complaints with the relevant regulatory authority, including NITDA

12. Data Security

We implement appropriate administrative, technical, and physical safeguards to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

13. Third-Party Links

Our website or applications may contain links to external websites or services. Koolboks is not responsible for the privacy practices or content of third-party platforms.

14. Updates to This Policy

We may update this Privacy Policy from time to time. Any updates will be published on our website with a revised effective date.

15. Contact Us