Privacy Policy

Kobopeer ("Kobopeer," "we," "us," or "our") respects the privacy of individuals who visit or use our website, application, marketplace, and related services.

This Privacy Policy explains how Kobopeer collects, uses, stores, discloses, and protects personal information.

It also explains the choices available to users and how to contact Kobopeer about privacy questions or requests.

Kobopeer is being developed as a peer-to-peer marketplace intended to help users discover and arrange exchanges between Nigerian naira (NGN) and supported foreign currencies.

The current Platform is a prototype that uses simulated balances and does not provide live-money transfers or operational escrow services.

The personal information processed by the prototype may differ from the information that a future live service would need to process.

This policy must be checked against the application's actual database, authentication provider, verification procedures, analytics, messaging integrations, and other services before publication.

Kobopeer will not claim to collect, verify, protect, or delete information through a process that has not actually been implemented.

The organization legally responsible for processing your personal information is:

Legal entity: Kobopeer Limited
Business name: Kobopeer
Business address: Plot 8, Providence Street, Lekki, Lagos
Privacy contact: Hello@kobopeer.com
Website: https://app.kobopeer.com

If Kobopeer uses a separate legal entity to operate the Platform, that entity must be identified accurately.

The information collected depends on how you use the Platform and which features are enabled.

Kobopeer should collect only information reasonably necessary for clearly identified and legitimate purposes.

The categories below describe information that may be relevant to the prototype or intended live service. They are not a statement that every category is currently collected.

3.1 Account and registration information

When you register or manage an account, Kobopeer may collect:

• Full name.

• Email address.

• Phone number, if requested.

• Account identifier.

• Account creation date.

• Account status.

• Authentication and session information.

• Password-reset and email-confirmation status.

• Preferences associated with your account.

Passwords should be handled by the authentication provider using secure password-storage mechanisms. Kobopeer should not store readable passwords in its application database.

Where authentication is provided by a third party, that provider may process information according to its own terms and privacy documentation.

3.2 Profile information

Depending on the features available, Kobopeer may collect or display:

• Profile name.

• Profile image, if provided.

• Account creation date.

• Verification status.

• Trading activity or history.

• Other profile information that you choose or are required to provide.

Information displayed to other users should be limited to what is necessary for the marketplace's operation and should be explained to users before it becomes visible.

3.3 Exchange and transaction information

When you create or participate in an exchange offer, Kobopeer may process information such as:

• The currencies involved.

• The proposed exchange amount.

• The proposed exchange rate.

• The offer's status.

• The transaction identifier.

• The identities or account identifiers of the participating users.

• Relevant timestamps.

• Payment instructions.

• Transaction status changes.

• Dispute records.

• Relevant communications or evidence submitted through the Platform.

In the current prototype, transaction information may be simulated.

A simulated transaction record does not establish that an actual payment occurred.

3.4 Bank-account information

A future live service may require certain bank-account details to identify the approved accounts to be used in a transaction.

Depending on the implementation, this could include:

• Account holder name.

• Bank name.

• Account number or an appropriately masked version.

• Bank or branch identifiers.

• Currency associated with the account.

• Verification status.

• A bank-issued transaction reference.

• Limited information about a verification deposit or challenge.

Bank-account details are sensitive information and should be handled with appropriate access controls.

Kobopeer should not collect or store online banking passwords, PINs, one-time banking authentication codes, or unrelated banking credentials.

The current prototype must not represent a bank account as independently verified unless a real verification process has actually been completed and validated.

3.5 Identity and verification information

If identity verification is introduced, Kobopeer may collect information reasonably required for the applicable verification process.

Depending on the provider and process, this could include:

• Legal name.

• Date of birth, if necessary.

• Country of residence.

• Identity-document information.

• Verification results.

• Reasons for a verification failure or review.

• Relevant information about the status of a verification request.

Kobopeer should not collect full identity documents merely because it may need them in the future.

The actual information collected, the identity-verification provider, the purposes of processing, and the retention arrangements must be disclosed before the process is activated.

3.6 Payment evidence and dispute information

If users submit evidence in connection with a transaction, Kobopeer may process information such as:

• Payment references.

• Bank-issued receipts.

• Relevant transaction screenshots.

• Transaction dates and amounts.

• Descriptions of the reported issue.

• Messages exchanged in connection with the dispute.

• Information needed to investigate suspected fraud.

Users should be instructed not to submit passwords, authentication codes, full card details, or unrelated personal information.

Kobopeer should restrict access to this material to authorized personnel and service providers with a legitimate need to process it.

3.7 Device and technical information

When you access the Platform, technical systems may process information such as:

• IP address.

• Browser type.

• Operating system.

• Device type.

• Approximate access time.

• Requested pages.

• Error reports.

• Security and diagnostic logs.

• Session identifiers.

• Other technical information generated by the application or hosting provider.

The precise information collected depends on the Platform's configuration and the services it uses.

Kobopeer should not claim to collect precise location information unless that functionality is actually enabled and appropriately disclosed.

3.8 Communications and support information

If you contact Kobopeer, we may process:

• Your email address or other contact details.

• The content of your inquiry.

• Information about your account or transaction that you choose to provide.

• Support correspondence.

• Complaint or dispute records.

• The steps taken to investigate or respond.

We use this information to respond to your request and maintain appropriate support records.

3.9 Referral and promotional information

If a referral programme is available, Kobopeer may process:

• Referral codes.

• The identity or account identifier of the referring user.

• The identity or account identifier of the referred user.

• Referral dates.

• Qualifying activity.

• Reward status.

• Records of any reward payment, if a live programme is implemented.

Simulated referral rewards do not represent actual payments.

Kobopeer should use appropriate controls to prevent referral abuse and unauthorized access to referral records.

Depending on the feature, information may be collected:

1. Directly from you when you register or complete a form.

2. When you create or accept an exchange offer.

3. When you communicate with Kobopeer support.

4. Through transaction or dispute workflows.

5. Automatically through the Platform's technical systems.

6. Through an authentication, hosting, verification, or other service provider.

7. From another participant in a transaction where the information is relevant to the transaction and may lawfully be provided.

8. From a bank or payment provider where a live integration exists and the disclosure is authorized.

Kobopeer should explain any material collection from sources other than the user, especially where that collection would not reasonably be expected.

Kobopeer may use personal information for the following purposes, to the extent applicable to the feature being used.

5.1 Account creation and authentication

We use account information to:

• Create and maintain user accounts.

• Authenticate users.

• Manage sessions.

• Support password recovery.

• Confirm email addresses where enabled.

• Protect accounts from unauthorized access.

5.2 Providing the marketplace

We may use information to:

• Display relevant exchange offers.

• Match offers with user preferences.

• Maintain profiles.

• Record transaction details.

• Display transaction statuses.

• Notify users about relevant activity.

• Operate the Platform's available features.

5.3 Verification and fraud prevention

Where implemented, we may use relevant information to:

• Confirm account details.

• Assess verification requests.

• Detect inconsistent or suspicious information.

• Investigate suspected fraud.

• Protect users and the Platform.

• Apply account restrictions where justified.

Verification must be limited to the purposes disclosed to users and must use an appropriate process.

5.4 Dispute handling

We may use transaction records, communications, payment references, and other relevant evidence to investigate a reported issue.

Access should be limited to information reasonably necessary to assess the matter.

5.5 Security and reliability

We may process technical information to:

• Detect unauthorized access.

• Investigate application errors.

• Prevent abuse.

• Diagnose technical failures.

• Maintain system integrity.

• Improve reliability and performance.

5.6 Communications

We may use contact information to send service-related communications, such as:

• Registration confirmation.

• Password-reset instructions.

• Security alerts.

• Important account notices.

• Transaction notifications, where available.

• Responses to support requests.

• Changes to terms or policies.

Marketing communications, where offered, should be managed in accordance with applicable law and the choices available to users.

5.7 Legal compliance

Where applicable, we may process information to:

• Comply with legal obligations.

• Respond to lawful requests.

• Maintain required records.

• Investigate suspected unlawful activity.

• Protect legal rights.

• Address security incidents.

Kobopeer will not claim to conduct regulated compliance checks that it has not actually implemented.

Kobopeer aims to provide clear information about its collection, use, and disclosure of personal information.

Where consent is required, we will seek consent in an appropriate form, taking into account the sensitivity of the information and the relevant legal requirements.

Certain processing may be necessary to provide a feature you request. Other processing may be optional.

Where appropriate, you may be able to decline an optional use of your information without losing access to unrelated features.

You may withdraw consent where permitted by applicable law, subject to legal or contractual restrictions and any consequences explained to you.

Withdrawing consent does not necessarily require Kobopeer to erase information that it must lawfully retain.

We will not treat acceptance of this Privacy Policy as permission to collect unlimited information or use it for unrelated purposes.

The Office of the Privacy Commissioner of Canada emphasizes meaningful consent, understandable disclosures about purposes and recipients, and meaningful choices concerning personal information.

Kobopeer does not sell personal information as a commercial mailing list.

We may disclose information in the following circumstances, where applicable and lawful.

7.1 Other marketplace users

Some information may be visible to other users because it is necessary to operate the marketplace.

Depending on the feature, this may include:

• A profile name.

• Relevant offer details.

• The currencies and amounts associated with an offer.

• Verification indicators.

• Transaction status.

• Information that must be shared to arrange or resolve a transaction.

Kobopeer should not display sensitive identity documents, full bank-account details, or unrelated private information publicly.

Where users must share payment details directly to complete a transaction, the Platform should clearly explain which details are shared, with whom, and for what purpose.

7.2 Hosting, database and authentication providers

Kobopeer may use service providers to host the application, store information, authenticate users, maintain backups, and provide related infrastructure.

These providers may process personal information on Kobopeer's behalf, subject to their applicable contractual arrangements and responsibilities.

The specific providers used must be identified or described accurately before this policy is published.

7.3 Communications providers

If Kobopeer uses an email, SMS, telephone, push-notification, or messaging provider, relevant contact details and message-delivery information may be processed to provide the communication.

For example, a phone-call notification provider may need a user's phone number and limited information about the notification.

Kobopeer should not send automated calls or marketing messages without the appropriate permissions and consent where required.

7.4 Banks and payment providers

A future live service may require sharing relevant transaction information with a bank, payment provider, or escrow service provider.

This may be necessary to execute or verify a payment, investigate a dispute, prevent fraud, or meet applicable legal obligations.

Kobopeer will not imply that a bank or payment-provider integration exists unless it has actually been implemented.

7.5 Identity and verification providers

If Kobopeer uses an external verification provider, the provider may process the information needed to perform the verification.

Before activating such a service, Kobopeer should explain what information is sent, why it is needed, and the provider's relevant role.

7.6 Professional advisers

Information may be disclosed to lawyers, accountants, auditors, insurers, or other professional advisers where reasonably necessary for legitimate business, legal, or compliance purposes.

7.7 Regulators, law enforcement and legal requests

Kobopeer may disclose information where required or permitted by law, including in response to a valid legal demand or to address suspected unlawful conduct.

We will assess requests as appropriate and disclose only the information that may lawfully be disclosed.

7.8 Business transfers

If Kobopeer undergoes a merger, acquisition, restructuring, or sale of assets, personal information may be transferred as part of that transaction, subject to applicable law and appropriate safeguards.

7.9 With your consent

We may share information with another recipient where you have given appropriate consent or instructed us to make the disclosure.

The Platform or its service providers may use cookies, local storage, session identifiers, and similar technologies.

Depending on the actual configuration, these technologies may be used to:

• Maintain login sessions.

• Remember user preferences.

• Support security.

• Maintain application functionality.

• Diagnose technical problems.

• Measure performance.

• Understand how users navigate the Platform.

The exact technologies used must be confirmed from the application's implementation.

If Kobopeer introduces analytics, advertising, or non-essential tracking technologies, the Platform should provide appropriate disclosures and consent choices where required by law.

You may be able to control certain cookies through your browser settings. Disabling some technologies may affect the operation of the Platform.

Kobopeer should not claim that it uses no cookies or tracking technologies unless that has been verified.

Kobopeer intends to use reasonable administrative, technical, and organizational safeguards appropriate to the sensitivity of the information it handles.

Depending on the system and feature, safeguards may include:

• Authentication and access controls.

• Role-based permissions.

• Encryption in transit.

• Appropriate protection of stored information.

• Secure password handling by the authentication provider.

• Monitoring for suspicious activity.

• Restrictions on administrative access.

• Backup and recovery procedures.

• Security testing.

• Incident-response procedures.

• Access logging for sensitive operations.

These examples describe safeguards that should be implemented where appropriate. They must not be treated as confirmation that every safeguard is currently in place.

No internet-based service can guarantee absolute security.

Users should protect their account credentials and report suspected unauthorized access promptly.

Kobopeer should never ask users to provide their online banking passwords or one-time banking authentication codes.

Kobopeer will retain personal information only for as long as reasonably necessary for the purposes described in this policy, subject to applicable legal requirements.

Retention periods may depend on:

• The type and sensitivity of the information.

• Whether an account remains active.

• Whether a transaction or dispute remains unresolved.

• Security and fraud-prevention requirements.

• Legal or regulatory obligations.

• The need to establish, exercise, or defend legal claims.

• Technical backup and recovery requirements.

For example:

• Account information may be retained while an account remains active.

• Support records may be retained for a reasonable period after an inquiry is resolved.

• Transaction and dispute records may require longer retention if a live service is introduced and applicable legal obligations require it.

• Security logs may be retained for a defined period appropriate to their purpose.

• Information that is no longer required should be deleted or de-identified, where appropriate and technically feasible.

Kobopeer should establish actual retention periods before launch rather than leaving sensitive information indefinitely in the database.

This policy does not establish a specific retention period where one has not yet been determined.

Where account deletion is available, users may request deletion through the account interface or the published support channel.

A deletion request will be handled in accordance with applicable law.

Depending on the circumstances, Kobopeer may need to retain certain information for legitimate and lawful purposes, such as:

• Complying with legal obligations.

• Maintaining required transaction records.

• Investigating suspected fraud.

• Resolving disputes.

• Protecting account security.

• Establishing or defending legal claims.

Where information must be retained, Kobopeer should limit its use to the relevant purpose and retain it only for the required or justified period.

Deleting an account does not necessarily remove all information from backups immediately. Where backup retention applies, the relevant information should be removed or overwritten in accordance with the applicable backup and deletion process.

The account-deletion process must reflect the actual capabilities of Kobopeer's authentication system and database.

Depending on the privacy laws applicable to your circumstances, you may have rights to:

• Request access to personal information held about you.

• Request correction of inaccurate information.

• Ask questions about how your information is used or disclosed.

• Withdraw consent where applicable.

• Request deletion where legally available.

• Challenge Kobopeer's compliance with applicable privacy requirements.

• Make a complaint to the relevant privacy regulator.

To make a privacy request, contact:

Privacy email: Hello@kobopeer.com

Please identify your request clearly and provide enough information for Kobopeer to locate the relevant records.

For security reasons, Kobopeer may need to verify your identity before providing access to sensitive information or completing a request.

We will respond in accordance with applicable law.

Some rights may be subject to exceptions or limitations.

Kobopeer may use service providers located in Canada or other countries.

Depending on the providers used, personal information may be processed or stored outside your province or country of residence.

The laws of the jurisdiction where information is processed may differ from the laws that apply where you live.

Before publication, Kobopeer should identify the actual locations and arrangements relevant to its hosting, database, authentication, and other material service providers.

Where cross-border processing occurs, Kobopeer will address applicable legal requirements and use appropriate contractual or other safeguards where required.

Kobopeer should not promise that all information is stored in Canada unless that statement has been verified.

Kobopeer is intended for individuals who are legally eligible to use the relevant service.

The Platform is not intended to collect children's personal information for an adult peer-to-peer currency-exchange service.

If Kobopeer introduces age or residency requirements, those requirements will be explained in the applicable service terms.

If we become aware that personal information has been collected in circumstances that violate applicable law or our stated eligibility rules, we will assess the matter and take appropriate action.

Kobopeer may provide service-related communications necessary to operate an account or respond to a user's request.

If promotional communications are offered, users will be provided with the choices and unsubscribe mechanisms required by applicable law.

A user should not be required to agree to unrelated marketing communications merely to register for essential account functionality, unless a lawful basis for that requirement exists.

Where applicable, promotional email and electronic messages will comply with Canadian anti-spam requirements.

Kobopeer may introduce automated telephone calls, SMS messages, push notifications, or other alerts to notify users about account activity or transaction events.

Before introducing such features, Kobopeer should explain:

• What types of events trigger a notification.

• Which contact details are used.

• Whether the communication is automated.

• How users can manage optional notifications.

• How notification preferences affect the service.

• How to report unwanted or incorrect communications.

Automated calls should not disclose unnecessary personal or financial information to an unverified recipient.

A call being answered, a key being pressed, or a message being delivered must not be treated as proof that a payment occurred or that an escrow-release condition has been satisfied.

Kobopeer may contain links to third-party websites or services.

Those services operate under their own terms and privacy policies.

Kobopeer is not responsible for the privacy practices of third-party websites that it does not control.

Users should review the privacy information of any third-party service before submitting personal information to it.

Kobopeer intends to maintain procedures for identifying, assessing, containing, and responding to privacy and security incidents.

If a breach occurs, Kobopeer will assess the incident and take the actions required by applicable law.

Depending on the circumstances, this may include:

• Investigating the nature and scope of the incident.

• Containing unauthorized access.

• Taking steps to protect affected accounts.

• Preserving relevant records.

• Notifying affected individuals where required.

• Reporting the incident to the appropriate regulator where required.

• Implementing measures to reduce the likelihood of recurrence.

Kobopeer should not promise that every incident will be prevented.

Kobopeer may update this policy to reflect changes in its services, information practices, technology, or legal obligations.

The updated policy will be published on the Platform with a revised "Last updated" date.

Where a material change requires additional notice or consent, Kobopeer will provide that notice or obtain consent as required by applicable law.

Users should review the policy periodically.

If Kobopeer begins collecting new categories of sensitive information, introduces a new verification provider, or materially changes how information is shared, the policy and any required consent process should be updated before the change is implemented.

For questions about this Privacy Policy or to exercise your privacy rights, contact:

Business: Kobopeer
Website: https://app.kobopeer.com
Email: Hello@kobopeer.com
Legal entity: Kobopeer Limited
Business address: Plot 8, Providence Street , Lekki , Lagos

Please include enough information for us to understand and respond to your request. Do not send passwords, one-time banking codes, or unnecessary identity documents by ordinary email.

If you are dissatisfied with our response, you may have the right to raise your concern with the privacy regulator responsible for your circumstances.