Privacy Policy

1. Introduction

Cudium is a cross-border online platform built to solve the problem of international payments. Making transactions easy, quick, safe, affordable, and transparent. We have our general office in Parakin, Ile-Ife, Osun state, Nigeria. We take the privacy of our users important.

This Privacy policy explains how we use users’ information, what we do with users’ information, how we collect them, where we store them, and how we secure and protect users’ information across payment gateways, APIs, Mobile wallets, software applications, and email notifications.

This privacy policy applies to all our platform(s) and it is a part of our terms and conditions. Thus, “Agreeing” to our terms and conditions means that you have agreed to our privacy policy. We recognize every device used by our users either, laptops, desktops, mobile phone, tablet, and any other electronic device use by our users.

Our privacy policy does not apply to services that are not rendered by Cudium.

Our Privacy policy may be modify from time to time. If we make changes to our privacy policy, users will be notified on our platforms. Thus, the continued usage of our platform means that you have agreed to the change(s) made.

2. Your Consent.

The process of using our platform may involve the use and disclosure of your information, including personal and biometric data (such as facial recognition data). You agree that Cudium may use some of this information as described in this privacy policy, particularly under the section “How We Use Your Data.” Your consent to the usage of the data we collect implies that you are a registered user of Cudium and that you have agreed to our terms regarding the collection of both personal and biometric data.

3. The Data we collect

During registration for a Cudium account and while using our services, we may collect the following personal data:

• Personal data:This refers to data that can be used to identify you, such as your name, email address, bank details, and phone number.
• Biometric data:When using certain features (such as identity verification), we may collect facial recognition data through technologies like ARKit and the TrueDepth API to verify your identity and ensure security.
  • Retention of Face Data: Face data is only stored locally on your device during the identity verification process and is deleted immediately after the process is completed. Cudium does not retain or store face data on its servers.
  • Reason for Collecting Face Data: We collect face data to ensure that the user undergoing identity verification is live and present, preventing fraud and ensuring accurate authentication during the KYC (Know Your Customer) process.
  • Length of Time Face Data is Stored: Face data is stored only for the duration of the identity verification process. Once the verification is completed, the face data is immediately deleted from your device and is not transmitted to or stored by Cudium. This ensures that face data is not retained beyond the necessary duration.

Other data may include:

• Your full name(s).
• Email.
• Date of birth.
• Government–issued identity card (which may include your international passport, driver’s license, voter’s card).
• Government-issued identity number.
• Bank verification number (BVN).
• A photograph (if applicable).
• 3D facial recognition data collected through your device’s camera (for identity verification).
• Other necessary information eligible for opening a Cudium account.

4. How we collect your data

You provide us with personal and biometric data when you:

• Open a Cudium Account.
• Use any of our services.
• Fill our online forms.
• Contact us or our customer support team.

Biometric data, such as facial recognition information, is collected during the identity verification process through your device’s camera and may use ARKit or TrueDepth API to capture facial data. This data is processed locally on your device to confirm your identity.

5. How we use your Data

We will use your personal information for the following purposes:

• To verify your identity during the KYC process, using facial recognition data to ensure that the user is live and prevent fraud.
• To create and manage your Cudium account(s), provide our services, and respond to your inquiries.
• To secure and prevent your account from unauthorized transactions and fraudulent activity.
• To process your payment transactions (including authorization, clearing, chargebacks and other related dispute resolution activities).
• To improve our business and services, including the use of data analytics.
• As necessary to establish, exercise and defend legal rights; As may be required by applicable laws and regulations, including Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over Cudium or affiliates.
• To Provide, administer and communicate with you about products, services, offers, programs and promotions of Cudium financial institutions, merchants and partners.
• To send you direct marketing communications about our products and services, subject to your approval and consent
• To maintain appropriate business record .
• For other reasons that will be communicated as the need arises.

6. How we share your Data

Cudium may share your data, including biometric data, with service providers, agents, employees, and affiliates as necessary to provide our services. We ensure that any third parties involved in processing this data adhere to strict privacy and security standards.

We do not share facial recognition or biometric data with third parties except as necessary for identity verification, fraud prevention, or as required by law. Biometric data collected via the TrueDepth API is processed locally on your device and is not transmitted to our servers or shared externally.

We may also share data:

• In case of mergers and/or acquisitions, with proper notification to users.
• To complete any transaction or provide any service you have requested or authorized.
• When required by law or to respond to legal processes.

7. Security of Data and Retention

Cudium prioritizes the security of the personal and biometric information of our users. We are intentional about the protection of user information and apply a general rule of keeping personal information only for as long as it is required to fulfill the purpose for which it was collected, including biometric data used for identity verification.

We maintain administrative, technical, and physical controls designed to protect the personal information you provide, or we collect, against loss, theft, unauthorized access, disclosure, copying, misuse, or modification. Our security measures include, but are not limited to, secure servers, firewalls, data encryption, and granting access only to authorized employees who require the information to fulfill their job responsibilities.

• Data Retention:Personal and biometric data is retained only for as long as necessary to meet legal, regulatory, or operational requirements. Biometric data, such as facial recognition information collected during the KYC process, is processed and used locally on your device and not stored on our servers. Any other personal data we retain will be securely stored in encrypted servers for the required period, after which it will be safely deleted or anonymized, unless we are legally required to retain it for longer.

When you close your account, we immediately stop sharing your data with third parties. Any data retained for legal or operational purposes will continue to be securely stored until no longer necessary, after which it will be deleted.

While Cudium is committed to protecting user data, it must be noted that transmitting information online is not entirely secure. Therefore, we cannot guarantee the security of information provided online. However, we will take all reasonable steps to ensure your information is protected within our systems and controls.

8. Users’ rights

Users’ rights shall include:

• Right to information on their Personal information collected and stored.
• Right to request access or copies to your Personal Information from us.
• Right to correct or rectify any Personal Information that you provide which may be incorrect, out of date or inaccurate.
• Right to object to the processing of your Personal Information for marketing purposes. You have a right to ask us not to contact you for marketing purposes by adjusting your notification preference on the settings page or by opting out via the unsubscribe link in the marketing emails we send you.
• Right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
• Right to withdraw consent. You also have the choice at any time to withdraw the consent which you have provided.
• Right to request that Cudium erase your Personal Information. You have the right to ask us to erase your Personal Information. Please note that this is a limited right that applies where the data is no longer required, or the processing has no legal justification. The exceptions to this right is where the applicable law requires us to retain a historical archive or where we retain a core set of your personal data to ensure we do not inadvertently contact you in the future when you object to your data being used for marketing purposes
• You may decline to provide your Personal Information when it is requested by Cudium. However, certain services or all the services may be unavailable to you.
• You may contact us at admin@cuduim.com to request more information on how your biometric data is handled or to raise concerns about your privacy rights.

9. Age restriction

Cudium is not intended for children under 18 years of age. We do not encourage anyone to provide us with information about under-age persons. You may contact us if you think we have information about under-aged persons. Contact us at admin@cuduim.com

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