Overview

This Privacy Policy describes your privacy rights regarding how and when we collect, use, store, share and protect your information across our website, payment platforms ("Platforms"), APIs, Software Applications, ("Apps"), email notifications and tools regardless of how you use or access them.

This Privacy Policy is applicable to all of the Website, software applications ("Apps") and/or payment platforms ("Platforms") offered by Fusion Intelligence Inc or its subsidiaries or affiliated companies collectively referred to as Fusion Intelligence "services".

"Fusion Intelligence", "we" "us" or "our" in this privacy statement means the Fusion Intelligence entity that is responsible for processing your personal information.

Definition

Account: means a Fusion Intelligence Account

Cookies: A cookie is a small data file that is transferred to your computer or mobile device. It enables us to remember your account log-in information, IP addresses, web traffic number of times you visit, browser type and version, device details, date and time of visits.

Fusion Intelligence means Fusion Intelligence Technologies Nigeria Limited.

Personal Information: Any information that can be used to identify a living person including email address, company name, password, payment card, financial information such as bank account number, etc.), Government-issued Identity card, Bank Verification Number (BVN) and/or taxpayer identification. It may also include anonymous information that is linked to you, for example, your internet protocol (IP), log-in information, address, location, device or transaction data.

Sites: means any platform including but not limited to mobile applications, websites and social media platforms.

User: means an individual who uses the Services or accesses the Sites and has agreed to use the end services of Fusion Intelligence.

Special Categories of Personal Information means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Objective

This privacy policy statement is to provide all persons and organizations whose personal data we hold with a description of the types of Personal Information we collect, the purposes for which we collect that Personal Information, the other parties with whom we may share it and the measures we take to protect the security of the data.

Accordingly, we have developed this privacy policy in order for you to understand how we collect, use, communicate, disclose and otherwise make use of personal information. We have outlined our privacy policy below.

Our Privacy Principles

Fusion Intelligence focuses on the following core principles:

• To Empower the individual: Fusion Intelligence wants you to be in charge of your personal information and to make your own voluntary choices about your personal data.
• To keep and secure personal information: Fusion Intelligence does not take your trusting us with your information for granted. We take responsibility for ensuring that appropriate security measures are put in place and your personal information is protected.
• To be transparent and to educate users: For you to know what personal information is, how we collect personal information, for what purpose and how we secure personal information.
• To abide by local laws: Fusion Intelligence is a company with local privacy expertise. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Specific privacy notices may apply to some of our products and services.
• To collect and store personal information on the "need to collect" basis: Fusion Intelligence collects personal information to perform its services for you. We work to have measures in place to prevent collecting and storing personal data beyond what we need.

Personal Information We May Collect About You

We may collect, use, process, store, or transfer personal information such as:

• Identity Data: Information such as your full name(s), your government-issued identity number, bank verification number (BVN) and your date of birth. This data is to enable us to verify your identity in order to offer our services to you.
• In order to experience the full range of our seamless services, we would require your consent granting access to your geo-location and your contacts. You have the right to withdraw your consent allowing us access to your contacts at any time.
• Contact Data: This is data that is needed to reach out to you, such as your contact address, email address, telephone number, details of the device you use and billing details.
• Identification documents: Such as your passport or any Government-issued identity card, a photograph (if applicable) and any other registration information you may provide to prove you are eligible to use our services.
• Log/Technical information: When you access Fusion Intelligence services, our servers automatically record information that your browser sends whenever you visit a website, links you have clicked on, length of visit on certain pages, unique device identifier, log-in information, location and other device details.
• Financial Data: Information, such as personal account number, the merchant's name and location, the date and the total amount of transaction, and other information provided by financial institutions or merchants when we act on their behalf.
• Transactional Data: These are information relating to a payment when you as a merchant (using one or more of our payment processing services) or as a customer, are using our products or services.
• Marketing and Communications Data: This includes a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties.
• Records of your discussions with us, if we contact you and if you contact us.

We may also collect, store, use and transfer non-personal information or anonymized data such as statistical or demographic data.

As a principle, we do not collect any Special Categories of Personal Information. If we do collect Special Categories of Personal Information, we will ensure compliance with applicable law.

This Privacy Policy applies to Fusion Intelligence services only. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies, plug-ins or other files on your computer, collect data or solicit personal information from you. Fusion Intelligence does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties' privacy statements.

How we get your Personal Information and why we have it

The Personal Information we have about you is directly made available to us when you:

• Sign up for a Fusion Intelligence Account/Product;
• Use any of our services;
• Contact our customer support team;
• Fill our online forms;
• Contact us.

The lawful basis we rely on for processing your Personal Information are:

• Your Consent: The data subject has given and not withdrawn consent for the specific processing.
• Contractual obligation: Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation: Processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., CBN AML/KYC regulations).
• Vital Interests: Processing is necessary to protect the vital interests of the data subject or another natural person (Life or Death situations).
• Public Interest tasks: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
• Legitimate interests: Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject.

Additional Legal Bases for Processing: Beyond consent and legal obligation, we process data under the following circumstances:

• Pre-Contractual Steps: Processing is necessary to take steps at the request of the data subject prior to entering into a contract (e.g., assessing a business application).
• Public Interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Fusion Intelligence by a statutory body.

How We May Use Your Personal Information

Personal data collected by Fusion Intelligence is obtained for specified, explicit, and legitimate purposes. We strictly prohibit the further processing of your data in any manner that is incompatible with the original purpose of collection. Any new processing activity that falls outside the original scope will require a fresh legal basis or explicit consent, except where such processing is for archiving in the public interest, scientific/historical research, or statistical purposes as permitted by the NDPA.

We may use the Personal Information we collect to:

• Create and manage any accounts you may have with us, verify your identity, provide our services, and respond to your inquiries;
• Process your payment transactions (including authorization, clearing, chargebacks and other related dispute resolution activities);
• Protect against and prevent fraud, unauthorized transactions, claims and other liabilities;
• Provide, administer and communicate with you about products, services, offers, programs and promotions of Fusion Intelligence, financial institutions, merchants and partners;
• Evaluate your interest in employment and contact you regarding possible employment with Fusion Intelligence;
• Evaluate and improve our business, including developing new products and services;
• To target advertisements, newsletter and service updates;
• As necessary to establish, exercise and defend legal rights;
• As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Fusion Intelligence or Fusion Intelligence's affiliates;
• To use data analytics to improve our Website, products or services, and user experiences.
• For other purposes for which we provide specific notice at the time of collection.

Data Security, Disposal Schedule and Retention

The security of your Personal Information is important to Fusion Intelligence. We are committed to protecting the information we collect. We maintain administrative, technical and physical controls designed to protect the Personal Information you provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse or modification.

Other security measures include but are not limited to, secure servers, firewalls, data encryption and granting access only to employees in order to fulfil their job responsibilities.

Where you use a password for any of your Accounts, please ensure you do not share this with anyone, and the password is kept confidential at all times.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Information is protected and maintained. Transmitting information online is not entirely secure. As such, we cannot guarantee that all information provided online is secure. We would take all reasonable steps to ensure that your Personal Information is secured and well protected.

Where an account is inactive and no legal obligation exists to keep the data, we will delete or anonymize such data within six (6) months of the purpose being fulfilled. Financial records may be kept longer as required by the Money Laundering Act.

Notwithstanding the above, transaction records and KYC data may be retained for up to 7 years to comply with the Money Laundering (Prevention and Prohibition) Act and Central Bank of Nigeria (CBN) regulations.

Upon expiry of the retention period, data is permanently deleted from our production databases and backup cycles using industry-standard secure erasure methods.

Transparency & Collection

In accordance with Section 27 of the NDPA, Fusion Intelligence ensures that you are informed of the following at the point of data collection:

• Identity of the Controller: Fusion Intelligence Technologies Nigeria Limited is the primary entity responsible for your data.
• Purpose of Processing: We collect data strictly for identity verification (KYC), transaction processing, and fraud prevention.
• Recipients of Data: Your data may be shared with our infrastructure providers (DigitalOcean), payment gateways, and regulatory bodies (CBN/NDPC) where legally required.
• Automated Decision-Making: We may use automated systems to flag suspicious transactions for fraud prevention. You have the right to request a manual review of any automated decision that significantly affects your account.

Regarding Automated Decisions

Fusion Intelligence respects your right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you.

• Human Intervention: If an automated system denies a transaction or restricts your account, you have the right to request human intervention to express your point of view and contest the decision.

Data Portability

You have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format (e.g., JSON or CSV). You also have the right to request that we transmit this data directly to another data controller where technically feasible, provided the processing is based on your consent or a contract.

Disclosing Your Personal Information

We may disclose or share your Personal Information with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, and subcontractors as may be reasonably necessary for the purposes set out in this policy.

Fusion Intelligence only shares personal information with External Third parties in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any personal information. We share Personal Information with third parties directly authorized by you to receive Personal Information, such as when you authorize a third party application provider to access your account. The use of your Personal Information by an authorized third party is subject to the third party's privacy policy and Fusion Intel shall bear no liability for any breach which may arise from such authorization by you.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
  • Satisfy any applicable law, regulation, legal process or enforceable governmental request;
  • Enforce applicable Terms of Service, including investigation of potential violations thereof;
  • Detect, prevent, or otherwise address fraud, security or technical issues; or
  • Protect against imminent harm to the rights, property or safety of Fusion Intel, its users or the public as required or permitted by law.
• If Fusion Intelligence becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

Marketing

We may process your Personal Information in order to contact you or send you marketing content and communication about our products, services or surveys. You may exercise your right to object to such contact from us or opt-out of the marketing content. Please note however that if you opt-out of marketing content, we may still send you messages relating to transactions and our Services related to our ongoing business relationship.

We may ask you for permission to send notifications to you. Our Services will still work if you do not grant us consent to send you notifications.

Your Data Protection Rights and Choices

Based on your location and applicable laws, below are the rights you have as a user in relation to your Personal Information:

• Right to be informed.
• Right to request access or copies to your Personal Information by signing into your Account or contacting us.
• Right to request that Fusion Intelligence erase your Personal Information. Please note that this is a limited right which applies where the data is no longer required, or the processing has no legal justification. The exceptions to this right is where the applicable law requires Fusion Intelligence to retain a historical archive or where we retain a core set of your personal data to ensure we do not inadvertently contact you in future where you object to your data being used for marketing purposes.
• Right to correct or rectify any Personal Information that you provide which may be incorrect, out of date or inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Right to object to the processing of your Personal Information for marketing purposes. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preference on the settings page or by opting out via the unsubscribe link in marketing emails we send you.
• Right to object to processing: You have the right to object to the processing of your Personal Information in certain circumstances. Please note that where you object to us processing your Personal Information, we might be unable to provide the services to you.

The basis of processing your Personal Information is your consent. You also have the choice at any time to withdraw the consent which you have provided.

You also have a choice to deactivate your Account at any time. You may contact us should you wish to de-activate your Account at any time.

If you wish to exercise any of the rights set above, please contact us using the contact information provided in the Contact Us section below. Where we are unsure of your identity, we might ask you for proof of your identity for security reasons before dealing with your request.

The Right to Withdraw Consent

You have the right to withdraw your consent for data processing at any time.

• How to Withdraw: You can toggle your preferences in the "Privacy Settings" of your Account Dashboard or click "Unsubscribe" in any marketing email.
• Effect of Withdrawal: Please note that withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal. If the data is required for a contractual or legal obligation (e.g., anti-money laundering records), we may be unable to delete it immediately.

Right to Object & Restrict

You have the right to object to the processing of your personal data for:

• Direct Marketing: You can object to receiving promotional content at any time.
• Profiling: You can object to your data being used to create a "user profile" for marketing purposes.
• Specific Circumstances: If you believe our "Legitimate Interest" in processing your data overrides your rights, you may object, and we will cease processing unless we demonstrate compelling legitimate grounds.

How to Exercise These Rights

To exercise any of the rights mentioned above (Access, Rectification, Erasure, Portability, or Objection), please follow these steps:

1. Submit a Request: Email our Data Protection Officer at dare@fusionintel.io.
2. Verification: For security, we will verify your identity before processing the request.
3. Timeline: We will acknowledge your request within 7 days and provide a substantive response within 30 days.

Cookies

We use cookies to distinguish you from other users and to customize and improve our services.

Some browsers may automatically accept cookies while some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable cookies, it may limit your ability to use our website. For detailed information on the cookies and how we use them see our Cookie Policy.

Minor

Fusion Intelligence's websites and applications are not directed at persons under the age of eighteen (18) and we do not collect any Personal Information knowingly or directly from minors who fall within this category.

Where you have any belief that Fusion Intelligence has mistakenly or unknowingly collected information from a minor, please contact us using the information provided under the Contact Us section to enable us to investigate and restrict such data.

International Data Transfers

Our business is global with affiliates and service providers located around the world. As such, Personal Information may be stored and processed in any country where we have operations. Also, your Personal Data may be transferred to countries which may not have the same data protection laws as the country you initially provided your Personal Information, but whenever we transfer or transmit your Personal Information internationally, we will ensure or take reasonable steps to ensure your Personal Information is handled securely in line with the applicable data protection laws and standard contractual clauses.

Your data is primarily processed and stored on secure infrastructure in Frankfurt (Germany) and the United Kingdom via DigitalOcean. These jurisdictions are recognized for providing an adequate level of protection. Transfers are governed by Standard Contractual Clauses (SCCs) and Data Processing Agreements to ensure compliance with the NDPA.

Governance & Accountability

Fusion Intelligence maintains a Record of Processing Activities (RoPA) as required by Section 24 of the NDPA. We have appointed a dedicated Data Protection Officer (DPO) to oversee our privacy strategy and act as the primary point of contact for data subjects and the NDPC.

• DPO Contact: dpo@fusionintel.io
• Internal Audits: We conduct annual internal privacy audits to ensure our technical and organizational measures remain effective against evolving security threats.

Processing Based on Consent of the Data Subject

When We Process Data Based on Consent

We may process your personal data when you have given us clear, freely given, specific, and unambiguous consent. This means we have your explicit permission to use your data for a stated purpose, and you have the freedom to refuse or withdraw your consent at any time without detriment.

Examples of Consent-Based Processing

• Marketing: Sending you promotional emails or newsletters after you have opted-in.
• Cookies: Using non-essential cookies to track your browsing habits after you have accepted them on a website.
• Account Creation: Collecting your personal information for a user account, with a clear statement of how that data will be used.
• Biometric Data: Collecting and using biometric data, such as fingerprints, for access control systems with your explicit consent.

Key Requirements for Valid Consent

• Freely Given: You must have a genuine choice, and we cannot make a service conditional on you giving consent for processing that is not necessary for that service.
• Specific: Your consent must be for a clear and specific purpose. We cannot use a single consent for multiple, unrelated processing activities.
• Informed: We must provide you with all necessary information before you consent, including our identity, the purposes of processing, the types of data collected, and your rights.
• Unambiguous: We must obtain consent through a clear affirmative action, such as ticking a box. Silence, pre-ticked boxes, or inactivity do not constitute valid consent.

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of any processing carried out before you withdrew it.

Processing for Performance of a Contract

When We Process Data for Contractual Obligations

We may process your personal data when it is necessary for the performance of a contract to which you are a party. This also applies when we need to take steps at your request before entering into a contract with you.

Examples of Contract-Based Processing

• Order Fulfillment: Processing your name, address, and payment information to deliver a product you have purchased.
• Service Delivery: Using your personal data to provide a service you have subscribed to (e.g., streaming service, software as a service).
• Booking and Reservations: Using your data to confirm a flight, hotel, or appointment booking.
• Account Management: Processing data to manage your account and provide you with customer support related to a service agreement.

Limitations and Considerations

Processing based on a contract must be strictly necessary to fulfill the terms of that contract. We cannot rely on this basis for processing activities that are not directly related to the contract.

Your data rights, such as the right of access and rectification, are still applicable. While you cannot object to processing that is necessary for the performance of the contract, you may still exercise other rights as appropriate.

Updates to our privacy policy

From time to time, we may change, amend or review this Privacy Policy to reflect new services or changes in our Privacy Policy and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Policy.

Contact Us

All access requests, questions, comments, complaints and other requests regarding the privacy policy should be sent to dare@fusionintel.io. You can also submit a physical correspondence to our office at 15, Saji Ayangade Street, Maryland, Lagos.

We may request additional details from you regarding your complaints and keep records of your requests and resolution.

This Privacy Policy was last updated on March 2026.