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VTUAgent · Legal

Privacy Policy

How we collect, use, share and protect your personal information when you use the VTUAgent app — and the much longer list of things we never touch at all.

Last updated
4 September 2026
Effective
4 September 2026
Stays on your phone

Held in the iOS Keychain or Android Keystore. Never transmitted, never received by us, and erased when you sign out.

  • Your app-unlock PIN
  • Face ID / Touch ID data
  • Session tokens
  • Theme and sign-in preferences

Your unlock PIN is hashed on the device before it is stored. Biometric data is held by Apple or Google in secure hardware — the operating system only tells the app “unlocked” or “not unlocked”.

Never collected

We use no advertising or analytics SDKs and do not track you across other companies’ apps. There is no tracking to consent to.

  • Location, precise or coarse
  • Your contacts
  • Your photo library
  • Camera or microphone
  • Health data
  • Advertising identifiers (IDFA)
  • Government ID photos or selfies
  • Card numbers or CVVs
  • Bank login credentials
  • Browsing history in other apps

The app has no card-entry screen and requests no device permission other than biometric unlock, which is optional.

Section01 · Summary

This Privacy Policy explains how VTUAgent (“VTUAgent”, “we”, “us”) collects, uses, shares and protects personal information when you use the VTUAgent mobile app and the services available through it (together, the “Service”).

VTUAgent is a Nigerian bill-payment service. You fund a wallet by bank transfer and use that balance to buy mobile airtime, mobile data bundles, cable TV subscriptions and prepaid electricity tokens. These are real-world goods and services delivered by mobile networks, broadcasters and electricity distribution companies.

If you do not agree with this Policy, please do not use the Service.

01

Summary

  • We collect only what is needed to open your account, verify you where the law requires it, deliver the products you pay for, and keep your money and account safe.
  • We do not sell your personal information.
  • We do not track you across other companies’ apps or websites, and we use no advertising or analytics SDKs. Apple’s App Tracking Transparency prompt therefore does not appear, because there is no tracking to consent to.
  • We do not collect your location, your contacts, your photos, or your device’s camera or microphone data.
  • You can delete your account from inside the app at any time: Profile \u2192 Delete account.
02

Information we collect

Split three ways: what you hand us, what your use of the Service creates, and what never leaves your phone.

2.1 — Information you give us

Full nameWhen Sign-upWhy Identifying your account; receipts; regulatory records
Email addressWhen Sign-upWhy Sign-in, email verification, transaction and security notices, support
PasswordWhen Sign-upWhy Securing your account. Stored only as a salted hash on our servers; never in readable form
Transaction PINWhen First purchase setupWhy Authorising purchases. Verified server-side; never displayed back to you
Phone numberWhen KYC Level 1, and when buying airtime or dataWhy Identity verification (confirmed by a one-time code) and delivering top-ups
Date of birth and genderWhen KYC Level 1Why Identity verification required of financial services in Nigeria
Bank Verification Number (BVN)When KYC Level 2 (optional upgrade)Why Confirming your identity with the bank registry so we can raise your transaction limits
Recipient details — phone, meter, smartcard numbersWhen Each purchaseWhy Delivering the exact product you paid for; support and dispute resolution
Support correspondenceWhen When you contact usWhy Answering you and keeping a record of the issue
Not requested, ever
We do not ask for or collect government ID photographs, selfies, passport or driver’s licence scans, card numbers, card CVVs, or bank login credentials. The app has no card-entry screen.

2.2 — Information created by your use of the Service

Wallet and transaction data
Your wallet balance; the dedicated Nigerian bank account number assigned to you for funding; funding transfers received; every purchase with its amount, product, provider, status, reference and timestamp; commission earned; and receipts.
Account status
Email-verification status, KYC level, account type (Personal or Agent), and whether a transaction PIN is set.
Session and device information
A device identifier generated by the app, the device name (for example “Joseph’s iPhone”), and session activity. This exists so that you can see the devices signed in to your account and sign any of them out remotely (Profile → Signed-in devices), and so that we can detect suspicious sign-ins.
Technical and security logs
IP address, timestamps, and error diagnostics generated when your device communicates with our servers. Used for security, fraud prevention and debugging.

2.3 — Stored only on your device, and never received by us

Your app-unlock PIN
If you set a PIN to unlock the app, it is converted on your device into a salted, stretched hash (PBKDF2-HMAC-SHA256) and stored in the iOS Keychain or Android Keystore. The PIN itself, and the hash, never leave your device and are never sent to us.
Face ID, Touch ID and biometric data
Biometric unlock is optional. Your fingerprint or face data is held by Apple or Google in the device’s secure hardware. VTUAgent never sees it, never receives it and cannot store it — the operating system only tells the app “unlocked” or “not unlocked”.
Session tokens
Held in the device’s secure storage so that you are not asked to sign in repeatedly. They are erased when you sign out or delete the app.
Local preferences
Theme choice, whether “Remember me” is on, and the email address you last signed in with — email only, never your password.

2.4 — Information we do not collect

We do not request or receive location data (precise or coarse), your contacts, your photo library, your camera, your microphone, your health data, your browsing history in other apps, or advertising identifiers such as the IDFA.

03

Permissions the app asks for

One, and it is optional.

Face ID and biometrics

Requested only if you choose to turn on biometric unlock. Declining it does not limit any feature — password sign-in always remains available.

The app requests no other device permissions.

04

How we use your information

We use personal information to:

  1. 01Create and operate your account, and sign you in securely.
  2. 02Verify your email address and, for KYC, your phone number and identity.
  3. 03Assign you a dedicated bank account number and credit your wallet when a transfer arrives.
  4. 04Process the purchases you authorise with your transaction PIN, and deliver those products to the phone line, meter or smartcard you specified.
  5. 05Calculate and display the commission discount applied to eligible purchases, and your earnings.
  6. 06Show your transaction history and generate receipts you can save, print or share.
  7. 07Comply with Nigerian financial-services obligations, including customer identification (KYC) and anti-money-laundering and anti-fraud rules, and respond to lawful requests from regulators and law-enforcement authorities.
  8. 08Detect, investigate and prevent fraud, account takeover, and abuse of the Service.
  9. 09Provide customer support and resolve disputed or failed transactions.
  10. 10Send service messages about your account and transactions, and maintain and improve the app’s reliability.

We do not use your data for behavioural advertising or profiling, and we do not make automated decisions that produce legal effects about you without human review.

Legal bases

Where the NDPA 2023, the GDPR or similar law applies.

Performance of a contract
Operating your wallet and delivering purchases.
Legal obligation
KYC, AML, tax and record-keeping duties.
Legitimate interests
Securing accounts, preventing fraud, and improving the Service.
Consent
Optional items such as biometric unlock, which you can withdraw at any time in the app’s settings.
05

How we share information

Only as described here, and only to the minimum extent needed.

Product providers
Mobile network operators (MTN, Airtel, Glo, 9mobile), cable TV broadcasters (such as DStv, GOtv and Startimes) and electricity distribution companies. They receive the recipient detail needed to deliver what you bought — the phone number, meter number or smartcard number, and the amount.
Our licensed Nigerian payment service provider
Issues and operates your dedicated funding account number and notifies us of incoming transfers, so your wallet can be credited.
Identity-verification partners and the bank verification registry
To confirm your phone number, date of birth and BVN when you choose to complete KYC.
Infrastructure providers
Hosting, database and email-delivery services acting on our instructions under contract, who may not use your data for their own purposes.
Regulators, courts and law-enforcement authorities
Where we are legally required to disclose, or where disclosure is necessary to investigate fraud or protect our users.
A successor entity
If VTUAgent is involved in a merger, acquisition or asset sale, your information may transfer, subject to this Policy.

Two technical services are contacted by the app itself: Google Fonts, which serves the typeface, and the Apple App Store, which the app queries to tell you when an update is available and to show Apple’s own rating prompt. Neither receives your account data. Ratings you submit go to Apple, not to us.

Our commitment
We never sell your personal information, and we never share it with advertisers or data brokers.
06

International transfers

We are based in Nigeria and process data there. Some infrastructure providers may store or process data outside Nigeria. Where that happens we rely on contractual safeguards requiring a level of protection consistent with the Nigeria Data Protection Act 2023 and, where applicable, standard contractual clauses.

07

How long we keep information

Account and profile data
For as long as your account is open.
Transaction, wallet and KYC records
Retained for the period Nigerian financial and anti-money-laundering law requires — currently a minimum of five years after the transaction or after the account closes, whichever is later.
Security and technical logs
Typically up to 12 months, unless needed for an ongoing investigation.
Support correspondence
Up to 24 months after the matter is closed.
Required by law
Transaction, wallet and KYC records survive account deletion, because Nigerian anti-money-laundering law requires us to keep them. They are held in restricted form and used for no other purpose.

When a retention period ends, data is deleted or irreversibly anonymised.

08

Deleting your account

Two ways to do it, and one thing to do first.

In the app

Profile → Delete account

You confirm with your password.

By email

[email protected]

Write from your registered email address.

Deletion closes your account permanently and revokes your sessions on every device.

Before you delete
Spend or withdraw your wallet balance first. A remaining balance is not automatically refunded on deletion. Records we must keep by law (see section 7) are retained in restricted form and are not used for any other purpose.
09

Security

  • All communication between the app and our servers uses HTTPS/TLS encryption.
  • Passwords are stored only as salted hashes; your transaction PIN is verified server-side and is never shown back to you.
  • Session tokens live in the iOS Keychain or Android Keystore, not in ordinary app storage. The access token is short-lived and held in memory.
  • Every purchase requires your transaction PIN, and the app can additionally be locked with Face ID, Touch ID or a local PIN.
  • You can review the devices signed in to your account and sign out any of them remotely.
  • If we detect that a session token has been reused or stolen, we end that session automatically.

No system is perfectly secure, but we work to protect your data and will notify you and the Nigeria Data Protection Commission of a breach affecting your personal data as the law requires.

10

Your rights

Subject to Nigerian law, and to the GDPR where it applies to you.

Access
The personal information we hold about you.
Correct
Information that is inaccurate or incomplete.
Delete
Your account and the data we are not legally required to keep.
Object or restrict
Certain kinds of processing.
Port
Receive a copy of the data you gave us, machine-readable.
Withdraw consent
For anything you consented to, such as biometric unlock, without affecting processing that already took place.

You may also complain to the Nigeria Data Protection Commission, or to your local supervisory authority.

To exercise any of these, email [email protected] from your registered address. We respond within 30 days. We may need to verify your identity before acting, to make sure we are not disclosing your data to somebody else.

11

Children

The Service is not directed to children. You must be 18 or older to open a VTUAgent account, as Nigerian financial-services rules require. We do not knowingly collect personal information from anyone under 18. If we learn that we have, we delete the account and its data. If you believe a minor has created an account, contact [email protected].

12

Marketing communications

We send transactional and security messages — such as email verification codes, transaction confirmations and account alerts — because they are part of the Service and cannot be turned off while your account is open. Any promotional email includes an unsubscribe link, and opting out never affects your ability to use the app.

13

Changes to this Policy

We may update this Policy as the Service or the law changes. The “Last updated” date at the top always reflects the current version. If a change materially affects how we use your information, we will tell you in the app or by email before it takes effect. Continuing to use the Service after a change means you accept the updated Policy.

14

Contact

VTUAgent

Published by XTRAHOLA CONCEPT

We aim to answer every privacy enquiry within 30 days.

[email protected]