Last Updated: October 9, 2025
IMPORTANT NOTICE: This Privacy Policy describes how Pairgate Venture ("Pairgate," "Company," "we," "us," or "our") collects, uses, discloses, and protects your personal information. By using our Platform, you consent to the data practices described in this Policy.
1.1 Application:
This Privacy Policy applies to all personal information collected through:
1.2 Acceptance:
By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, you must immediately discontinue use of the Platform.
1.3 Changes to Policy:
We reserve the right to modify this Privacy Policy at any time. Changes are effective immediately upon posting. Your continued use after changes constitutes acceptance. We may notify you of material changes via email or Platform notification, but we are not obligated to do so.
1.4 Age Restrictions:
The Platform is not intended for persons under 18 years of age. We do not knowingly collect personal information from minors. If we discover we have collected information from a minor, we will delete it promptly.
1.5 Incorporation into Terms:
This Privacy Policy is incorporated into and forms part of our Terms and Conditions. Capitalized terms not defined herein have the meanings assigned in the Terms and Conditions.
For purposes of this Privacy Policy:
3.1 Information You Provide Directly:
A. Registration and Account Information:
B. Financial and Payment Information:
C. Verification Documents:
D. Communication Information:
E. Transaction Information:
3.2 Information Collected Automatically:
A. Device and Technical Information:
B. Usage and Analytics Data:
C. Location Information:
D. Cookies and Tracking Technologies:
3.3 Information from Third Parties:
A. Identity Verification Services:
B. Payment Processors:
C. Social Media Platforms:
D. Data Brokers and Marketing Partners:
E. Telecommunications Providers:
F. Public Sources:
3.4 Inferred Information:
We may derive or infer additional information about you based on data we collect, including:
4.1 Service Provision and Account Management:
4.2 Security and Fraud Prevention:
4.3 Legal and Regulatory Compliance:
4.4 Platform Improvement and Analytics:
4.5 Marketing and Communications:
4.6 Business Operations:
4.7 Personalization:
4.8 Other Purposes:
We process your personal information based on the following legal grounds:
5.1 Contractual Necessity:
Processing is necessary to perform our contract with you (Terms and Conditions) and provide Services.
5.2 Legal Obligations:
Processing is necessary to comply with legal obligations, including KYC/AML laws, tax laws, and regulatory requirements.
5.3 Legitimate Interests:
Processing is necessary for our legitimate business interests, including:
5.4 Consent:
Where required by law, we process personal information based on your consent, which you may withdraw at any time.
5.5 Vital Interests:
Processing may be necessary to protect vital interests of you or another person.
5.6 Public Interest:
Processing may be necessary for tasks carried out in the public interest.
6.1 Service Providers and Business Partners:
We share information with third-party service providers who perform services on our behalf:
6.2 Financial Institutions and Payment Networks:
6.3 Telecommunications and Utility Providers:
6.4 Government and Regulatory Authorities:
6.5 Legal and Professional Advisors:
6.6 Business Transaction Parties: In connection with mergers, acquisitions, asset sales, or corporate restructuring:
6.7 Affiliated Companies:
6.8 Marketing and Advertising Partners:
6.9 Credit Bureaus and Risk Assessment Agencies:
6.10 Public Disclosure:
We may publicly disclose:
6.11 With Your Consent:
We may share information with other parties when you provide consent or direct us to do so.
6.12 Aggregate and De-Identified Data:
We may share aggregated, anonymized, or de-identified data that cannot reasonably identify you for any purpose.
7.1 Cross-Border Transfers:
The Platform is operated from Nigeria. Your personal information may be transferred to, stored in, and processed in Nigeria and other countries where we or our service providers operate.
7.2 Different Privacy Laws:
Countries outside your residence may have different data protection laws. By using the Platform, you consent to the transfer of your information to countries that may not provide the same level of protection as your country.
7.3 Safeguards:
We implement appropriate safeguards for international transfers, which may include:
7.4 No Guarantee:
We cannot guarantee that data protection laws in other countries will provide the same level of protection as your home country.
8.1 Retention Periods:
We retain personal information for as long as necessary to:
8.2 Specific Retention Periods:
A. Account Information:
B. Transaction Records:
C. Identity Verification Documents:
D. Communications:
E. Technical and Usage Data:
F. Legal and Compliance Records:
8.3 Extended Retention:
We may retain information longer when:
8.4 Deletion:
When information is no longer needed, we will:
However, deletion from backup systems may take additional time.
8.5 Right to Request Deletion:
You may request deletion of your personal information, subject to our legal and operational requirements. See Section 11 for details.
9.1 Security Measures:
We implement reasonable technical, physical, and administrative security measures to protect personal information, including:
Technical Measures:
Physical Measures:
Administrative Measures:
9.2 No Absolute Security:
Despite our efforts, no security measures are completely secure. We cannot guarantee absolute security of your information. Internet transmission and electronic storage carry inherent risks.
9.3 Your Responsibilities:
You are responsible for:
9.4 Security Breaches:
In the event of a data breach affecting your personal information:
9.5 Third-Party Security:
We cannot guarantee the security practices of third-party service providers, websites, or platforms. You use third-party services at your own risk.
10.1 Types of Cookies We Use:
A. Essential Cookies:
B. Analytics Cookies:
C. Marketing Cookies:
D. Third-Party Cookies:
10.2 Other Tracking Technologies:
10.3 Cookie Management:
You can control cookies through:
Note: Disabling essential cookies may affect Platform functionality.
10.4 Do Not Track:
We do not currently respond to "Do Not Track" browser signals.
10.5 Mobile Device Identifiers:
Mobile devices use advertising identifiers that can be reset or limited in your device settings.
11.1 Access Rights:
You may request:
11.2 Correction and Update:
You may:
11.3 Deletion:
You may request deletion of your personal information, subject to:
We may retain some information in backup systems for a limited time.
11.4 Restriction of Processing:
You may request that we limit how we use your information in certain circumstances.
11.5 Data Portability:
You may request a copy of your personal information in a structured, commonly used, machine-readable format.
11.6 Object to Processing:
You may object to processing based on legitimate interests or for direct marketing purposes.
11.7 Withdraw Consent:
Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
11.8 Opt-Out of Marketing:
You may opt-out of marketing communications by:
Note: You cannot opt-out of essential service communications.
11.9 Exercising Your Rights:
To exercise your rights, contact us at:
We may request identification to verify your identity before responding to requests.
11.10 Response Time:
We will respond to requests within 30 days, or as required by applicable law. We may extend this period for complex requests.
11.11 Right to Complain:
You have the right to lodge a complaint with the Nigerian Data Protection Commission or other relevant supervisory authority if you believe we have violated your privacy rights.
11.12 Limitations on Rights:
Your rights may be limited by law or when:
12.1 Age Restriction:
The Platform is not intended for persons under 18 years of age. We do not knowingly collect personal information from children under 18.
12.2 Parental Consent:
If you are under 18, you must obtain parental or guardian consent before using the Platform.
12.3 Deletion of Children's Data:
If we discover we have collected information from a child under 18 without proper consent, we will delete it promptly.
12.4 Parental Rights:
Parents or guardians may:
Contact us immediately if you believe we have collected information from a child without proper consent.
13.1 Third-Party Links:
The Platform may contain links to third-party websites, services, or applications. We are not responsible for their privacy practices.
13.2 Third-Party Privacy Policies:
Third-party sites have their own privacy policies. We encourage you to review them before providing personal information.
13.3 Social Media Features:
Social media features on the Platform are governed by the privacy policies of the respective social media platforms.
13.4 No Endorsement:
Links to third-party sites do not constitute endorsement of their privacy practices or content.
13.5 Your Responsibility:
You are responsible for reviewing third-party privacy policies and deciding whether to use third-party services.
14.1 Automated Decisions:
We may use automated decision-making, including:
14.2 Profiling:
We create user profiles based on:
14.3 Right to Human Review:
You may request human review of automated decisions that significantly affect you.
14.4 Right to Explanation:
You may request explanation of the logic, significance, and consequences of automated decision-making.
15.1 Types of Communications:
We may send you:
15.2 Consent:
By providing your contact information, you consent to receive marketing communications unless you opt-out.
15.3 Opt-Out:
You may opt-out at any time through:
15.4 Essential Communications:
You cannot opt-out of essential service communications (transaction confirmations, security alerts, legal notices).
15.5 Third-Party Marketing:
We may share your information with marketing partners. You may opt-out of such sharing by contacting us.
If you are a California resident, you have additional rights under the California Consumer Privacy Act:
16.1 Right to Know:
You have the right to request disclosure of:
16.2 Right to Delete:
You have the right to request deletion of your personal information, subject to exceptions.
16.3 Right to Opt-Out of Sale:
While we do not "sell" personal information in the traditional sense, you have the right to opt-out of certain data sharing practices.
16.4 Right to Non-Discrimination:
You have the right not to receive discriminatory treatment for exercising your CCPA rights.
16.5 Authorized Agent:
You may designate an authorized agent to make requests on your behalf.
16.6 Exercising CCPA Rights:
To exercise your rights, contact us at: contact@pairgate.com with subject "CCPA Request"
16.7 Verification:
We will verify your identity before responding to requests.
16.8 Response Time:
We will respond within 45 days, extendable by an additional 45 days for complex requests.
If you are located in the EEA or UK, you have additional rights under GDPR:
17.1 Legal Basis:
We process your data based on contract performance, legal obligations, legitimate interests, or consent as described in Section 5.
17.2 Enhanced Rights:
17.3 Supervisory Authority:
You have the right to lodge a complaint with your local data protection authority.
17.4 Data Protection Officer:
For significant data processing issues, contact: contact@pairgate.com (marked "Data Protection Officer")
17.5 International Transfers:
We use appropriate safeguards for transfers outside the EEA/UK, including standard contractual clauses.
18.1 Nigeria Data Protection Regulation (NDPR):
We comply with the Nigeria Data Protection Regulation 2019 and guidelines issued by the National Information Technology Development Agency (NITDA).
18.2 Lawful Processing:
We process personal data lawfully, fairly, and transparently for specified, explicit, and legitimate purposes.
18.3 Data Protection Principles:
We adhere to principles of:
18.4 Data Protection Officer:
We have designated personnel responsible for data protection compliance.
18.5 Rights under NDPR:
You have the right to:
18.6 Data Breach Notification:
We will notify NITDA and affected individuals of data breaches as required by NDPR.
18.7 Contact for NDPR Matters:
Email: contact@pairgate.com (Subject: "NDPR Compliance")
19.1 Right to Modify:
We reserve the right to modify this Privacy Policy at any time in our sole discretion.
19.2 Notice of Changes:
We will notify you of material changes by:
19.3 Effective Date:
Changes are effective immediately upon posting unless otherwise stated.
19.4 Continued Use:
Your continued use of the Platform after changes constitutes acceptance of the modified Privacy Policy.
19.5 Review Responsibility:
You are responsible for regularly reviewing this Privacy Policy for updates.
20.1 Privacy Inquiries:
For questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us:
Pairgate Venture
Email: Support@pairgate.com
Website: https://pairgate.com
20.2 Data Protection Officer:
For data protection matters:
Email: Support@pairgate.com (Subject: "Data Protection Officer")
20.3 Privacy Rights Requests:
To exercise your privacy rights:
Email: Support@pairgate.com (Subject: "Privacy Rights Request")
20.4 Response Time:
We aim to respond to all inquiries within 30 days, or as required by applicable law.
20.5 Complaints:
If you are not satisfied with our response, you may lodge a complaint with:
Nigeria Data Protection Commission (NDPC) / NITDA
Website: https://nitda.gov.ng
By using the Platform, you:
22.1 Language:
This Privacy Policy is written in English. Any translated versions are provided for convenience only. In case of conflict, the English version prevails.
22.2 Severability:
If any provision is found invalid or unenforceable, the remaining provisions remain in full force and effect.
22.3 Governing Law:
This Privacy Policy is governed by the laws of Nigeria.
22.4 Integration:
This Privacy Policy, together with our Terms and Conditions, constitutes the complete agreement regarding privacy practices.
Pairgate is a comprehensive fintech platform with enhanced features that allows members to make passive income as VTU selling agents while enjoying discounted bill payments for airtime, data bundles, electricity, cable TV services and many more. We are duly registered with the Corporate Affairs Commission (CAC - 3687598).