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"). This policy applies to our website, mobile applications, customer support channels, and related services. Where consent is required, we request it separately; other processing may be necessary to perform our agreement with you, comply with law, protect legitimate interests, or establish and defend legal claims.

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 • App version, security device identifiers, push-notification tokens, request identifiers, and diagnostic events

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 diagnose failures, measure service reliability, and improve our services using minimized, aggregated, or de-identified information where practical • Rights requests — To verify and process access, correction, restriction, objection, portability, and deletion requests

We use technical and organizational safeguards appropriate to the sensitivity of the information, including: • Encryption in transit and security controls for sensitive stored information • Restricted access to identity documents and sensitive operational records • Database, infrastructure, logging, backup, and administrative access controls • Audit trails, authentication controls, and monitoring intended to prevent unauthorized access or alteration We retain personal data only for as long as needed for the purposes described above. After an account deletion request is completed, we delete or anonymize information that is no longer required. Financial transaction, KYC, fraud-prevention, tax, dispute, and audit records may be retained for periods required by applicable law or legitimate regulatory obligations. Retained records are restricted from ordinary product use.

We do not sell your personal data to third parties. We may share limited data with the following trusted partners: • Payment and banking infrastructure providers, including Platnova where used, for virtual accounts, wallet funding, contributions, verification, and payouts • Identity-verification and secure-document providers used to complete KYC checks • Cloud, database, storage, security, and content-delivery providers, including Railway, AWS, and Cloudflare where used • Expo, Apple, Google, and push-notification infrastructure needed to build, distribute, update, and notify users of the mobile app • Email, SMS, WhatsApp, and customer-support providers used for transactional communications and support • Professional advisers, auditors, regulators, courts, law enforcement, or counterparties where disclosure is legally required or necessary to protect legal rights We require processors to handle information only for documented purposes and to apply appropriate confidentiality and security safeguards. Some providers may process information outside Nigeria; where this occurs, we use the transfer safeguards required by applicable law.

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. The mobile app does not rely on browser cookies for authentication; it stores authentication credentials in protected device storage and may use essential device storage for security and app preferences.

Under the Nigeria Data Protection Act 2023, applicable NDPC guidance, and other applicable laws, you may 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 request account deletion, use the Delete Account option in the PrimeHC mobile app or visit https://primeheritage.org/account-deletion. For other privacy rights, contact privacy@primeheritagecommunity.com. We may verify your identity before acting and will respond within the period required by applicable law.

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 where required and without undue delay • Report the incident to relevant regulatory authorities within applicable legal timeframes • 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 Where a material change requires new consent or another action, we will request it before the change applies to the relevant processing.

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