Privacy Notice

1. Controller and scope

Profynix Technology, operator of TopMonie, determines how personal data is used for the app and is the controller for that processing. Some payment and identity partners act as separate controllers for services they independently provide.

This Notice applies to the app, support channels and related services. Privacy questions and data-rights requests may be sent to topmonie@profynix.com.

2. Data we collect

• Identity and contact data such as name, date of birth, phone, email and user tag.
• Verification data such as BVN when required, verified bank-account details and verification results.
• Financial and transaction data including balances, beneficiaries, instructions, fees, references and dispute records.
• Conversation and voice data submitted to the assistant and the intent needed to answer or prepare an action.
• Device, session, network, security and diagnostic information.
• Profile, preferences, beneficiaries, budgets, notifications and optional AI memory.
• Support communications, complaints and documents you choose to provide.

3. Why we process data

• Contract: to open and operate an account, execute instructions, provide receipts and support services.
• Legal obligation: identity, fraud, anti-money-laundering, recordkeeping and regulatory activities.
• Legitimate interests: security, abuse prevention, reliability, performance and legal claims after considering your rights.
• Consent: optional marketing, permissions or AI-memory uses where consent is appropriate.
• Vital or public interests where law permits and circumstances require.

4. AI and automated processing

Automated systems understand messages, detect intent, personalise assistance, identify suspicious activity and prepare transactions. Money does not move merely because AI generated a response.

For a qualifying decision with legal or similarly significant effect based solely on automation, you may request human intervention, express your view and contest the decision, subject to lawful fraud-prevention limits.

5. Who receives data

We share only reasonably necessary data with regulated account and payment providers, banks, switches, billers, identity providers, telecommunications and messaging providers, cloud, AI, security and analytics providers, advisers and lawful authorities.

We do not sell personal data. Partners must receive data under an appropriate legal basis and contractual or statutory safeguards.

6. International transfers

Some technology providers may process data outside Nigeria. We rely on a mechanism permitted by the Nigeria Data Protection Act and apply required contractual, organisational and technical safeguards.

7. Retention

We keep data only as long as needed for its purpose and applicable legal, accounting, fraud-prevention and dispute requirements. Account, transaction, acceptance and complaint records may generally remain for the relationship and up to six years afterwards, or longer where lawfully required.

Optional AI memory can be reviewed or deleted in the app. Deleting memory does not erase transaction or compliance records retained independently.

8. Security

We use layered administrative, technical and physical safeguards including access controls, encryption where appropriate, monitoring and incident response. No system is risk-free. Reportable breaches are notified as required.

9. Your rights

• Be informed and obtain access to your personal data.
• Correct inaccurate or incomplete information.
• Request erasure or restriction where legal conditions apply.
• Object to legitimate-interest processing or direct marketing.
• Withdraw consent where processing relies on consent.
• Receive portable data where applicable.
• Challenge qualifying solely automated decisions.
• Complain to TopMonie or the Nigeria Data Protection Commission.

10. Children and changes

TopMonie is not intended for anyone under 18 and does not knowingly open accounts for children.

We may update this Notice as services or laws change. Material changes are communicated and, where required, fresh consent is requested.

11. Contact

Data protection contact: topmonie@profynix.com. Operator: Profynix Technology. CAC registration number: RC 8770418.