Privacy Policy

1. Introduction

Cudium ("we/us") is a cross-border payment platform headquartered in Ile-Ife, Osun State, Nigeria. This policy explains how we handle your personal data.

What this covers: Applies to all Cudium services (website, mobile apps, APIs). Does not cover third-party services.

2. Your Consent

By using Cudium, you agree to:

• Collection of personal data (name, ID, contact details)
• Temporary biometric processing (facial recognition for identity checks)

Key point: Face scans are processed on your device only – we never store them

3. Data We Collect

Personal Information:

• Full name, email, phone number
• Government IDs (passport, driver's license, BVN)
• Transaction history

Biometric Data (for verification only):

• Facial scan via your device's camera
• Used once and immediately deleted

4. How We Use Your Data

We use your information to:

✔️ Verify your identity and prevent fraud

✔️ Process payments securely

✔️ Improve our services

✔️ Comply with Nigerian financial laws

✔️ Send service updates (marketing only with your opt-in)

5. Data Sharing

We may share with:

• Banks/Payment processors (to complete transaction
• Regulators (when required by law)
• Service providers (under strict confidentiality)

Never shared: Your biometric data stays on your device unless legally required.

6. Data Security

We protect your data with:

• Bank-grade encryption
• Regular security audits
• Limited staff access

Breach response: We notify authorities within 72 hours if any incident occurs.

7. Your Rights

You can:

→ Get a copy of your personal data

→ Correct inaccurate information

→ Delete data we don't need to keep

→ Delete data we don't need to keep

→ Withdraw consent for face verification

How to exercise: Email dpo@cudium.com – we'll respond as soon as possible

8. Data Retention

• Biometric data: Deleted immediately after use
• Account info: Kept while active
• Transaction records: 5 years (financial regulation requirement)

9. Age Restriction

❌ No users under 18. Report accidental underage accounts to admin@cudium.com.

10. Cookies

We use cookies to:

• Keep you securely logged in
• Remember preferences
• Improve our platform

Your control: Adjust settings in your browser.

11. Policy Updates

We'll notify you:

• By email for major changes
• Via app notifications for minor updates

Your continued use means you accept changes.