The full privacy policy.

Your privacy as a Kehbar user is very important to us, and Kehbar Limited (“Kehbar”, “we”, “us”, or “our”) is committed to safeguarding your personal data. We are committed to collecting and processing personal data responsibly and only to the extent necessary to provide our Services and comply with applicable laws.

We collect and process personal data on a “need-to-collect” basis and ensure that appropriate technical and organisational measures are put in place to protect your personal data.

This Privacy Policy applies to all systems, operations, and processes within our environment that involve the collection, storage, use, transmission, and disposal of personal data.

Kehbar is a technology platform that facilitates the recording, management, administration, tracking, and coordination of financial arrangements and transactions between users. Kehbar is not a bank, deposit-taking institution, payment service provider, money transmission operator, or other regulated financial institution unless expressly stated otherwise. Financial services that may be made available through the Platform, including virtual accounts, payment processing, collections, settlements, and related services, are provided by licensed third-party financial institutions, payment service providers, banks, and other regulated partners. Kehbar does not hold customer deposits, provide banking services, or directly process regulated financial transactions.

Our intelligent assistant, Berit is an automated assistance feature designed to help users manage activities on the Platform. Berit does not provide legal, financial, investment, tax, accounting, or professional advice, and users remain solely responsible for reviewing and making decisions regarding any information, suggestions, reminders, summaries, recommendations, or outputs generated by Berit.

Kehbar does not guarantee repayment of loans, recovery of debts, performance of savings groups, contributions, investments, pooled funds, or any financial arrangement created through the Platform. Users remain solely responsible for evaluating and managing their financial relationships and transactions.

This Privacy Policy explains how Kehbar Limited (“Kehbar”, “we”, “us”, or “our”) collects, uses, stores, processes, and protects your personal data when you access or use the Kehbar platform, including our website, mobile application, virtual account features, payment and collection tools, savings and contribution management features, community and group management tools, Berit (our intelligent assistant feature), and all related products, features, functionalities, and services (collectively, the “Platform” or “Services”).

We are committed to protecting your privacy and handling your personal data in accordance with applicable data protection laws, including the Nigeria Data Protection Act and any other applicable data protection or privacy laws. This Privacy Policy should be read together with our Terms of Service, which govern your use of the Platform.

By accessing or using the Platform, you consent to the collection, use, storage, and processing of your personal data in accordance with this Privacy Policy. For the purposes of applicable data protection laws, Kehbar Limited acts as the data controller in relation to personal data collected and processed through the Platform, except where Kehbar processes personal data on behalf of another party in which case Kehbar may act as a data processor.

By accessing, registering on, or using the Kehbar platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection, use, storage, processing, and disclosure of your personal data in the manner described in this Privacy Policy.

Where we require your consent to process your personal data for a specific purpose, we will request such consent at the point of data collection, and you will have the option to accept or decline such processing.

You have the right to withdraw your consent at any time where processing is based on your consent. However, withdrawal of consent shall not affect the lawfulness of any processing carried out prior to the withdrawal of consent. Please note that if you withdraw your consent for certain processing activities, we may be unable to provide some or all of the Services to you.

By providing personal data relating to another person (such as a borrower, lender, or other third party) on the Platform, you represent and warrant that you have obtained the consent of that person to provide their personal data to Kehbar for processing in accordance with this Privacy Policy.

Where required by law, we may also seek your explicit consent before collecting or processing certain sensitive personal data.

We collect personal data and other information in order to provide, operate, improve, and secure the Platform and the Services. The type of information we collect depends on how you interact with the Platform and the Services you use.

1. Information You Provide to Us

We collect personal information that you voluntarily provide when you register for an account, use the Platform, create or participate in loan agreements, contact us, join the waitlist, or otherwise communicate with us. This information may include your full name, email address, phone number, residential address, date of birth, profile information, login credentials (including usernames and encrypted authentication credentials), government-issued identification, Bank Verification Number (BVN), selfie photographs and biometric verification information, utility bills or proof of address, any information required for KYC, KYB, AML, sanctions screening, or regulatory compliance purposes, and any other information you choose to provide to us.

2. Financial Activity Information

Because Kehbar provides tools for creating, managing, tracking, documenting, facilitating, and administering loans, contributions, dues, savings arrangements, community funds, pooled contributions, and other financial arrangements between users, we may collect and store information relating to such arrangements on the Platform. This information may include loan amounts, repayment schedules, repayment history, disbursement records, payment confirmations, outstanding balances, due dates, notes added by users, messages between users within the Platform, uploaded proof of payment or supporting documents, agreement terms entered by users, and agreement status and performance history.

You acknowledge that loan and agreement information entered on the Platform will be visible to the other party involved in the agreement.

3. Information Collected Automatically

When you access or use the Platform, we may automatically collect certain technical and usage information, including IP address, device type, device identifier, browser type, operating system, log data, usage data, pages visited, features used, date and time of access, referral urls, location data (when enabled), cookies and tracking technologies, etc.

4. Information from Third Parties

We may receive information about you from third parties, including identity verification service providers, payment service providers, analytics providers, communication service providers, business partners, authentication (SSO) and social login providers, and other users who enter your information when creating an agreement involving you.

5. Information from Website Visitors

You may visit our website without providing personal information. However, we may collect non-personally identifiable information such as browser type, device information, pages visited, and usage data for analytics, security, and website improvement purposes.

6. Financial and Transaction Information

In connection with the financial features available through the Platform, we may collect and process financial and transaction information, including virtual account details, bank account information, account names and account numbers, payment transaction records, collection records, settlement records, account funding records, transaction counterparties, payment destination information, financial institution identifiers, wallet identifiers, savings and contribution records, group contribution records, dues payment records, beneficiary information, payout and withdrawal records, transaction reference numbers, transaction status information, and information received from payment service providers and financial institution partners.

7. Community and Group Information

Where you participate in a savings group, contribution pool, cooperative, dues collection programme, rotating savings arrangement, community fund, or other group-based financial activity through the Platform, we may collect and process group membership information, group contribution records, group payment history, group administrator information, group communications, group transaction activity, group payout records, and roles, permissions, and administrative actions taken by group administrators or authorised group representatives.

8. Virtual Account Information

Where virtual account services are made available through the Platform, we may collect and process information relating to virtual account creation, account assignment, account usage, transaction history, settlement activity, and related financial information necessary for the operation of such services.

9. Berit Interaction Information

Where you interact with Berit, we may collect and process information relating to your use of the feature, including questions, prompts, instructions, and requests submitted to Berit, responses generated by Berit, information contained in messages, reminders, records, agreements, transactions, or other content processed by Berit, usage logs and interaction history, feedback provided regarding Berit’s performance, and technical information relating to your use of Berit.

Such information may be processed for the purpose of providing Berit functionality, improving the Platform, troubleshooting issues, enhancing user experience, ensuring security, and complying with legal obligations. Berit may utilise artificial intelligence and machine learning technologies provided by Kehbar or third-party service providers.

10. Sensitive Personal Data

In certain circumstances, we may collect sensitive personal data for identity verification and compliance purposes, including government-issued identification and Bank Verification Number (BVN). Such information will be collected and processed only where necessary and in accordance with applicable laws.

We use the information we collect for various purposes, including to provide, operate, maintain, improve, and secure the Platform and the Services. We may use your information for the following purposes:

1. To Provide and Operate the Services

We use your information to create and manage your account, enable you to create and manage loans, contributions, savings arrangements, dues collections, community funds, pooled contributions, and other financial activities, record and track payments and repayments, maintain shared records between users, send reminders and notifications, and provide all other features of the Platform.

2. To Facilitate User Transactions and Financial Arrangements

We use the information you provide to create, manage, and maintain records relating to loans, repayments, savings activities, dues collections, contributions, virtual account transactions, and other financial arrangements between users on the Platform. Information relating to a loan agreement is shared with the other party involved in that agreement for the purpose of enabling both parties to view and track the agreement.

3. To Communicate with You

We may use your information to communicate with you regarding:

• Your account;
• Loans, repayments, contributions, dues, savings activities, collections, virtual account activity, and transaction reminders;
• Service updates;
• Security alerts;
• Changes to our Terms or Privacy Policy;
• Customer support responses;
• Administrative messages;
• Newsletters and marketing communications (where you have consented to receive such communications).

4. For Identity Verification and Compliance

We may use your information to verify your identity, conduct KYC (Know Your Customer) checks, prevent fraud, detect illegal activities, comply with legal and regulatory obligations, and enforce our Terms of Service.

We may also conduct anti-money laundering (AML), counter-terrorism financing (CTF), sanctions screening, politically exposed person (PEP) screening, fraud screening, and other compliance checks either directly or through third-party service providers.

5. To Improve the Platform and Services

We may use information for analytics, research, product development, troubleshooting, data analysis, testing, system maintenance, and to improve the functionality, reliability, and user experience of the Platform.

6. To Provide Berit Functionality

We may process personal data, transaction information, communications, contribution records, repayment records, group information, and other information available on the Platform in order to enable Berit to generate reminders, notifications, summaries, recommendations, suggested actions, reports, and other assistance requested by users.

Information processed through Berit may be used to improve the accuracy, functionality, reliability, security, and performance of the Platform and the Berit feature.

7. For Security and Fraud Prevention

We may use your information to monitor activity on the Platform, detect suspicious activity, prevent fraud, enforce our Terms of Service, and protect the rights, property, and safety of Kehbar, our users, and third parties.

8. For Legal Purposes

We may use your information where necessary to:

• Comply with applicable laws and regulations;
• Respond to lawful requests by government authorities;
• Respond to user complaints;
• Enforce our Terms of Service;
• Establish, exercise, or defend legal claims.

9. Transaction Monitoring and Dispute Resolution

We may use personal data and transaction information to investigate payment disputes, verify transactions, resolve user complaints, and comply with requests from financial institutions and payment service providers.

10. Regulatory Compliance

We may process personal data where necessary to comply with anti-money laundering laws, counter-terrorism financing laws, sanctions regulations, tax laws, financial services regulations, consumer protection laws, court orders, and other legal or regulatory requirements applicable to the Platform or its service providers.

11. Marketing and Promotional Communications

Where you have provided your consent, we may use your email address or phone number to send you newsletters, product updates, promotional materials, and other marketing communications. You may opt out of marketing communications at any time by following the unsubscribe instructions in our messages, by adjusting your account settings, or by contacting us directly.

12. Aggregated and Anonymised Data

We may use aggregated or anonymised data for analytics, research, product improvement, and business purposes. Such data does not identify you personally.

Kehbar may provide features that enable users to make, receive, record, manage, monitor, or track payments, contributions, dues, savings, collections, transfers, and other financial transactions through regulated third-party financial institutions and payment service providers.

In connection with these features, we may collect, process, use, and share personal data and transaction information as necessary to generate virtual accounts, process collections and payments, verify transactions, facilitate settlement and reconciliation, prevent fraud, conduct compliance checks, resolve transaction disputes, and comply with legal and regulatory obligations.

Payment services available through the Platform may be provided by licensed financial institutions, banks, payment service providers, or other regulated third parties. Users should refer to the Important Disclaimer above regarding the role of Kehbar and the provision of financial services through licensed third-party partners

We process your personal data in accordance with applicable data protection laws, including the Nigeria Data Protection Act. Our legal basis for collecting and using your personal data depends on the specific information concerned and the context in which we collect it. We rely on one or more of the following legal bases:

1. Consent

We process your personal data where you have given us your consent to do so. This includes situations where you create an account, provide personal information, agree to receive communications, or otherwise voluntarily provide your personal data through the Platform.

You have the right to withdraw your consent at any time. However, withdrawal of consent shall not affect the lawfulness of processing carried out before such withdrawal. Please note that if you withdraw your consent for certain processing activities, we may be unable to provide some or all of the Services to you.

2. Performance of a Contract

We process your personal data where it is necessary for the performance of a contract with you or to take steps at your request before entering into a contract. This includes processing necessary to create and manage your account, provide the Services, maintain loan records, facilitate agreements between users, and provide customer support.

3. Legal Obligation

We may process your personal data where it is necessary for compliance with a legal or regulatory obligation. This includes identity verification, fraud prevention, law enforcement requests, regulatory compliance, and record-keeping obligations.

4. Legitimate Interests

We may process your personal data where it is reasonably necessary for our legitimate business interests, provided that such interests do not override your fundamental rights and freedoms. These legitimate interests include:

• Operating and improving the Platform;
• Ensuring the security of the Platform;
• Preventing fraud and illegal activities;
• Communicating with users;
• Providing customer support;
• Conducting analytics and research;
• Enforcing our Terms of Service;
• Record and preserve information relevant to disputes between users;
• Protecting the rights, property, and safety of Kehbar, our users, and third parties.

Where we rely on legitimate interests as a legal basis, we will take appropriate steps to ensure that your rights and interests are not overridden by our legitimate interests.

Kehbar does not sell, rent, or trade your personal data to third parties. However, we may share or disclose your personal data in the following circumstances and for the purposes described below:

1. With Other Users

Because Kehbar enables users to create, manage, participate in, and administer loans, savings groups, contribution pools, dues collection arrangements, community funds, and other financial activities, certain information relating to those activities may be shared with other authorised participants involved in the relevant arrangement. This may include your name, contact details, loan amount, repayment schedule, repayment history, payment confirmations, uploaded documents, and any other information relating to the agreement. By using the Platform and entering into an agreement, you consent to the sharing of your information with the other party to that agreement.

2. With Service Providers

We may share your personal data with third-party service providers who perform services on our behalf or help us operate the Platform and provide the Services. These service providers may include:

• Cloud storage providers;
• Identity verification providers;
• Payment service providers;
• Communication and email service providers;
• Analytics providers;
• Security and fraud prevention providers;
• Customer support service providers;
• Hosting and infrastructure providers.

These third parties are authorised to use your personal data only as necessary to provide services to us and are contractually required to maintain the confidentiality and security of your personal data.

We may share information processed through Berit with technology providers, cloud service providers, artificial intelligence service providers, machine learning service providers, and other service providers engaged by Kehbar for the purpose of providing, supporting, securing, maintaining, or improving Berit and related Platform functionality. Such providers will be subject to appropriate contractual confidentiality and data protection obligations.

3. With Financial Institution and Payment Partners

We may share personal data, transaction information, identity verification information, and financial information with regulated financial institutions, payment service providers, banks, virtual account providers, settlement providers, payment gateways, and other financial partners where necessary to provide financial features through the Platform.

Such sharing may be necessary for virtual account creation, payment processing, transaction settlement, fraud prevention, identity verification, regulatory compliance, anti-money laundering compliance, customer support, and dispute resolution.

4. With Affiliates and Related Companies

We may share your personal data with our affiliates, subsidiaries, or related companies where necessary for business operations, service delivery, compliance, analytics, and administrative purposes.

5. For Legal and Regulatory Purposes

We may disclose your personal data where we believe in good faith that such disclosure is reasonably necessary to:

• Comply with applicable laws, regulations, legal processes, or governmental requests;
• Enforce our Terms of Service or other agreements;
• Investigate, prevent, or address fraud, security, or technical issues;
• Respond to claims or disputes;
• Protect the rights, property, or safety of Kehbar, our users, or the public;
• Establish, exercise, or defend legal claims.

We may disclose personal data and transaction information to regulators, law enforcement agencies, financial intelligence units, courts, governmental authorities, tax authorities, or other competent authorities where required by applicable law, regulatory obligation, court order, subpoena, investigation, or lawful request.

6. Business Transfers

If Kehbar is involved in a merger, acquisition, restructuring, financing, or sale of assets, your personal data may be transferred as part of that transaction. In such circumstances, we will take reasonable steps to ensure that your personal data continues to be protected in accordance with this Privacy Policy.

7. With Your Consent

We may share your personal data with third parties where you have given us your consent to do so or where you have authorised a third-party application or service to access your information.

8. Aggregated or Anonymised Data

We may share aggregated or anonymised data that does not identify you personally with third parties for analytics, research, business, or statistical purposes.

Kehbar may engage third-party service providers, vendors, and partners (“Third-Party Processors”) to process personal data on our behalf for the purpose of providing, operating, maintaining, and improving the Platform and the Services.

These Third-Party Processors may include providers of the following services:

• Cloud hosting and data storage services;
• Identity verification and KYC services;
• Payment processing and payment integration services;
• Communication services such as email, SMS, and push notifications;
• Analytics and performance monitoring services;
• Security and fraud detection services;
• Customer support and helpdesk services;
• Infrastructure and technology service providers.

Where we engage Third-Party Processors to process personal data on our behalf, we ensure that such processing is governed by a written contract which requires the Third-Party Processor to:

• Process personal data only on Kehbar’s documented instructions;
• Implement appropriate technical and organisational security measures to protect personal data;
• Ensure confidentiality of personal data;
• Not engage another processor without authorisation;
• Comply with applicable data protection laws;
• Assist Kehbar in complying with its data protection obligations;
• Return or delete personal data at the end of the service relationship where applicable.

Kehbar does not permit Third-Party Processors to use your personal data for their own independent purposes, and they are only permitted to process personal data for specific purposes and in accordance with our instructions.

While we take reasonable steps to ensure that our Third-Party Processors protect your personal data, Kehbar shall not be responsible for the acts or omissions of such Third-Party Processors except to the extent required by applicable law.

In the course of providing the Platform and Services, your personal data may be transferred to, stored in, or processed in countries outside the Federal Republic of Nigeria. This may occur where our servers, service providers, or Third-Party Processors are located in other countries.

Where your personal data is transferred outside Nigeria, Kehbar will take appropriate steps to ensure that your personal data is protected and transferred in accordance with applicable data protection laws, including the Nigeria Data Protection Act.

We will ensure that at least one of the following safeguards is in place before transferring personal data outside Nigeria:

• The country to which the personal data is transferred has been recognised as having an adequate level of data protection;
• The transfer is necessary for the performance of a contract between you and Kehbar, or for the implementation of pre-contractual measures taken at your request;
• The transfer is necessary for the conclusion or performance of a contract concluded in your interest between Kehbar and a third party;
• You have provided your consent to the transfer;
• The transfer is necessary for reasons of public interest;
• The transfer is necessary for the establishment, exercise, or defence of legal claims;
• The transfer is necessary to protect your vital interests or the vital interests of another person where you are physically or legally incapable of giving consent.

Kehbar will take all reasonable steps to ensure that any personal data transferred outside Nigeria is treated securely and in accordance with this Privacy Policy. Where required, we will enter into data transfer agreements with the receiving party to ensure adequate protection of your personal data.

You may contact us if you would like more information about how we transfer personal data outside Nigeria and the safeguards we have in place.

Kehbar will retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purpose of providing the Services, complying with legal and regulatory obligations, resolving disputes, enforcing agreements, preventing fraud, and protecting the legal rights and interests of Kehbar and its users.

The period for which we retain personal data is determined based on several factors, including:

• The nature and type of personal data collected;
• The purpose for which the personal data was collected and processed;
• Whether there is an ongoing contractual relationship between you and Kehbar;
• Whether the data is required for the performance of the Services;
• Whether there are legal, regulatory, tax, accounting, or reporting obligations requiring us to retain the data;
• Whether the data is required for the establishment, exercise, or defence of legal claims;
• Whether the data is required for fraud prevention and security purposes;
• Whether there is a pending dispute, investigation, or legal claim;
• Whether you have requested deletion of your personal data;
• Whether retention is required for legitimate business purposes.

We may retain certain records relating to loans, repayments, contributions, dues collections, savings arrangements, virtual accounts, transactions, communications, identity verification, compliance records, and account activity for a reasonable period even after your account has been closed or inactive, where such retention is necessary for legal, regulatory, dispute resolution, audit, fraud prevention, or enforcement purposes.

Where personal data is no longer required for the purpose for which it was collected, we will take reasonable steps to delete, destroy, anonymise, or de-identify such personal data in accordance with applicable laws and our data retention policies.

Please note that we may retain anonymised or aggregated data for analytics, research, and business purposes, and such data will not identify you personally.

Kehbar is committed to the principle of data minimisation and will only collect, process, and retain personal data that is relevant, adequate, and limited to what is necessary for the purposes for which it is collected and processed.

We do not collect personal data that is not required for the operation of the Platform, the provision of the Services, compliance with legal obligations, fraud prevention, security monitoring, dispute resolution, or other legitimate business purposes.

Where possible, Kehbar will use anonymised, aggregated, or de-identified data instead of personal data, particularly for analytics, research, system improvement, and business intelligence purposes.

We will periodically review the personal data we collect and retain to ensure that it is still necessary for the purpose for which it was collected. Where personal data is no longer required, we will securely delete, anonymise, or destroy such data in accordance with our data retention and deletion policies.

Users are advised not to upload or submit personal data that is not necessary for the creation, administration, management, or participation in activities available through the Platform. Kehbar shall not be responsible for personal data voluntarily uploaded by users that is not required for the use of the Services.

Kehbar collects and processes personal data only for specific, explicit, and legitimate purposes related to the operation of the Platform and the provision of the Services. These purposes include account creation and management, identity verification, creation and management of loans, contribution arrangements, dues collections, savings groups, community funds, virtual accounts, transaction processing, payment tracking, communication between users, customer support, security monitoring, fraud prevention, legal compliance, and improvement of the Platform and Services.

We will not process personal data for purposes that are incompatible with the purposes for which the data was originally collected, unless we obtain your consent or such processing is required or permitted by law.

Where we intend to use personal data for a new purpose that is materially different from the original purpose for which the data was collected, we will notify you and, where required, obtain your consent before such processing.

Kehbar will ensure that personal data collected is adequate, relevant, and limited to what is necessary for the stated purposes and will not retain personal data for longer than is necessary for those purposes, except where retention is required by law or for the establishment, exercise, or defence of legal claims.

Kehbar may use your contact information, including your email address and phone number, to send you communications relating to the Platform and the Services. These communications may include service-related messages, administrative messages, security notifications, updates about the Platform, product announcements, newsletters, promotional materials, and other marketing communications.

Service-related communications include messages that are necessary for the operation of your account and the provision of the Services, such as account verification messages, repayment reminders, agreement updates, technical notices, security alerts, and changes to our Terms of Service or Privacy Policy. You may not be able to opt out of service-related communications where such communications are necessary for the proper functioning of the Platform and the provision of the Services.

Where we send marketing or promotional communications, we will do so only where permitted by applicable law or where you have provided your consent to receive such communications. You have the right to opt out of receiving marketing communications at any time by using the unsubscribe link in our emails, adjusting your account settings, or contacting us directly.

Please note that even if you opt out of marketing communications, we may still send you service-related communications that are necessary for your use of the Platform.

We do not sell your personal data to third parties for marketing purposes and we do not permit third parties to send you marketing communications without your consent.

Kehbar uses cookies and similar tracking technologies to collect information about your use of the Platform and to improve the functionality and performance of the Platform. Cookies are small text files that are stored on your device when you visit a website or use an application.

We may use cookies and similar technologies for the following purposes:

• To identify you as a user and maintain your login session;
• To remember your preferences and settings;
• To enable certain features of the Platform;
• To improve the performance and functionality of the Platform;
• To analyse usage and user behaviour;
• To monitor and analyse traffic on the Platform;
• To enhance security and prevent fraud;
• To customise content and improve user experience.

Cookies may be either session cookies (which expire when you close your browser) or persistent cookies (which remain on your device until deleted).

We may also use third-party analytics providers who use cookies and similar technologies to collect information about your use of the Platform in order to help us analyse usage patterns, improve our Services, and enhance user experience.

Most web browsers allow you to control cookies through browser settings. You may choose to disable cookies through your browser settings; however, please note that disabling cookies may affect the functionality of the Platform and some features may not work properly.

Our cookies do not store sensitive personal information such as passwords or financial information. Cookies typically store anonymous identifiers, device information, and usage information.

By continuing to use the Platform, you consent to the use of cookies and similar tracking technologies as described in this Privacy Policy.

You may visit the Kehbar website without creating an account or providing personal information. However, when you visit our website, we may automatically collect certain non-personally identifiable information to help us understand how visitors use our website and to improve our Services.

This information may include:

• Your IP address;
• Browser type and version;
• Device type;
• Operating system;
• Pages visited;
• Time and date of visits;
• Referring website addresses;
• Clickstream data;
• General location information (such as city or country);
• Website usage data and analytics information.

We collect this information through cookies, server logs, analytics tools, and similar tracking technologies.

This information is used for the following purposes:

• To administer and maintain our website;
• To monitor website performance;
• To improve website functionality and user experience;
• To analyse website traffic and usage patterns;
• To enhance security and prevent fraud;
• To support marketing and advertising activities;
• To diagnose technical issues.

Where non-personally identifiable information is combined with personal data, we will treat the combined information as personal data and handle it in accordance with this Privacy Policy.

If you choose to provide personal information through our website, such as by joining a waitlist, contacting us, subscribing to updates, or creating an account, we will collect and process that personal information in accordance with this Privacy Policy.

Kehbar takes the security of your personal data seriously and is committed to protecting your personal data from unauthorized access, loss, misuse, alteration, disclosure, or destruction. We implement appropriate technical, administrative, and organisational measures designed to protect personal data in our possession or under our control.

Our security measures include, but are not limited to:

• Secure servers and encrypted data storage;
• Secure Sockets Layer (SSL) encryption for data transmission;
• Firewalls and network security controls;
• Access control measures and role-based access restrictions;
• Multi-factor authentication where applicable;
• Password protection and secure authentication systems;
• Data encryption and hashing technologies;
• System monitoring and logging;
• Regular security reviews and system updates;
• Internal policies and procedures for data protection;
• Limiting access to personal data to authorised personnel only;
• Confidentiality obligations for employees, contractors, and service providers.

We also require our Third-Party Processors to implement appropriate security measures to protect personal data in accordance with applicable data protection laws and industry standards.

Kehbar may monitor accounts, transactions, devices, IP addresses, user behaviour, and platform activity for the purposes of detecting fraud, abuse, suspicious activity, security incidents, money laundering risks, sanctions violations, and other unlawful activities.

While we take reasonable steps to protect your personal data, please note that no method of transmission over the internet or method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security of your personal data. You are responsible for maintaining the confidentiality of your account credentials and for ensuring that your login information is not shared with any third party.

If we become aware of a data breach that is likely to result in a risk to your rights and freedoms, we will take appropriate steps to investigate, contain, and mitigate the breach and notify affected users and relevant authorities where required by applicable law.

Kehbar takes data breaches seriously and has procedures in place to detect, investigate, and respond to personal data breaches. A personal data breach includes any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Kehbar will take appropriate steps to contain, investigate, and mitigate the breach in a timely manner.

Where required by applicable law, Kehbar will notify the relevant data protection authority and affected users of the breach within the time prescribed by law. Such notification may include:

• The nature of the data breach;
• The categories of personal data affected;
• The likely consequences of the breach;
• The measures taken or proposed to address the breach;
• Steps users may take to protect themselves;
• Contact details for further information.

Kehbar will document all data breaches, including the facts relating to the breach, its effects, and the remedial action taken.

Users also have a responsibility to keep their account credentials secure. If you become aware of any unauthorized access to your account, loss of your login credentials, or any suspected data breach, you must notify us immediately at help@kehbar.com so that we can take appropriate action.

Subject to applicable data protection laws, including the Nigeria Data Protection Act, you have certain rights in relation to your personal data collected and processed by Kehbar. These rights include the following:

1. Right of Access

You have the right to request access to the personal data we hold about you and to obtain information about how we process your personal data.

2. Right to Rectification

You have the right to request that we correct or update any inaccurate or incomplete personal data that we hold about you.

3. Right to Erasure

You have the right to request the deletion of your personal data where:

• The personal data is no longer necessary for the purpose for which it was collected;
• You withdraw your consent where processing is based on consent;
• You object to processing and there are no overriding legitimate grounds for processing;
• The personal data has been unlawfully processed;
• Deletion is required to comply with a legal obligation.

Please note that we may not be able to delete your personal data where retention is required for legal, regulatory, dispute resolution, fraud prevention, or enforcement purposes.

4. Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to processing.

5. Right to Object to Processing

You have the right to object to the processing of your personal data where processing is based on legitimate interests. We will consider your request and will stop processing your personal data unless we have compelling legitimate grounds to continue processing.

6. Right to Data Portability

Where technically feasible, you have the right to request that your personal data be provided to you in a structured, commonly used, and machine-readable format and to request that such data be transferred to another service provider.

7. Right to Withdraw Consent

Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

8. Right to Object to Automated Decision-Making

You have the right to object to decisions made solely by automated means where such decisions have legal or significant effects on you. Notwithstanding, Kehbar does not use Berit to make solely automated decisions that produce legal effects concerning users without appropriate human involvement, except where permitted by applicable law. Users remain responsible for reviewing and approving actions generated or suggested by Berit.

9. Right to Lodge a Complaint

If you believe that your personal data has been processed in a manner that violates applicable data protection laws, you have the right to lodge a complaint with the relevant data protection authority.

10. Exercising Your Rights

You may exercise any of your rights by contacting us at help@kehbar.com. We may request additional information to verify your identity before processing your request. We will respond to your request within the time required by applicable law.

The Kehbar Platform and Services are not intended for use by persons under the age of eighteen (18) or the legal age of majority where they reside, and we do not knowingly collect, process, or store personal data from individuals under the legal age of majority.

By using the Platform, you represent and warrant that you are at least 18 years of age or the legal age of majority in your country of residence, and have the legal capacity to enter into a binding agreement.

If we become aware that we have collected personal data from a person under the age of 18 or the legal age of majority without appropriate parental or guardian consent, we will take steps to delete such personal data as soon as reasonably practicable.

If you are a parent or guardian and you believe that a minor has provided personal data to us without your consent, please contact us at help@kehbar.com, and we will take appropriate steps to investigate and delete such information where necessary.

Kehbar shall not be liable for any use of the Platform by a person under the age of 18 or the legal age of majority in violation of these Terms or this Privacy Policy.

Kehbar reserves the right to update, modify, revise, or change this Privacy Policy from time to time in order to reflect changes in our business practices, services, legal obligations, or regulatory requirements.

Where we make material changes to this Privacy Policy, we will take reasonable steps to notify you of such changes. Such notification may be provided through the Platform, by email to the email address associated with your account, through in-app notifications, or by publishing an updated version of this Privacy Policy on our website.

Unless otherwise stated, any changes to this Privacy Policy will take effect from the date the updated Privacy Policy is published on the Platform.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal data.

Your continued use of the Platform after any changes to this Privacy Policy have taken effect shall constitute your acceptance of the updated Privacy Policy.

If you do not agree with the updated Privacy Policy, you should stop using the Platform and may request that we close your account and delete your personal data, subject to our data retention obligations under applicable law.

If you have any questions, concerns, complaints, or requests regarding this Privacy Policy, the processing of your personal data, or your rights under applicable data protection laws, you may contact us using the details below:

Kehbar Limited
Email: help@kehbar.com

You may contact us for any of the following reasons, including but not limited to:

• To request access to your personal data;
• To request correction or update of your personal data;
• To request deletion of your personal data;
• To request restriction of processing of your personal data;
• To object to the processing of your personal data;
• To withdraw consent previously given;
• To request transfer of your personal data to another service provider (data portability);
• To report a data breach or security incident;
• To make a complaint regarding how your personal data is being processed.

When you contact us, we may request certain information from you to verify your identity before we process your request. This is to ensure that your personal data is not disclosed to any unauthorized person.

We will respond to your request within a reasonable time and in accordance with applicable data protection laws.

If you are not satisfied with our response to your complaint or believe that your personal data is being processed in a manner that violates applicable law, you may lodge a complaint with the relevant data protection authority in Nigeria.

This Privacy Policy is effective as of June 8, 2026.