Privacy Policy
Last Updated: May 21, 2026
Qugo ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, process, and share your personal information when you use our mobile application ("QugoApp").
1. Information We Collect
To provide our cross-border payment and currency swap services, we collect information that identifies, relates to, describes, or could reasonably be linked with you ("Personally Identifiable Information" or "PII"). This includes:
- Identity Data: Full name, date of birth, nationality, email address, phone number, and residential address.
- Government Identifiers: Bank Verification Number (BVN) and National Identification Number (NIN) in accordance with regulatory requirements.
- Financial Data: Bank account details, transaction history, swap records, and wallet addresses.
2. Biometric Data Processing & KYC Disclosures
In compliance with international Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) standards, as well as the Central Bank of Nigeria guidelines, we are required to verify the identity of our users.
Facial Verification and Liveness Checks: We collect and process biometric data, specifically facial images and mathematical representations of your facial geometry, to perform liveness detection and identity checks. This processing is executed through our authorized third-party identity verification partners, Prembly and Smile ID.
By initiating the identity verification process, you explicitly consent to the collection, processing, and transfer of your biometric data to these partners solely for identity validation and fraud prevention. Biometric data is never stored on our servers and is handled strictly in accordance with applicable data protection laws.
3. How We Use Your Information
We use your information to operate QugoApp, process swaps, verify identity, prevent fraudulent activities, comply with legal obligations, and provide customer support. Qugo does not sell, rent, or lease your Personally Identifiable Information to third parties for marketing purposes.
4. Data Sharing and Third-Party Integrations
We share your information only with trusted partners essential to providing our services:
- Clearing & Liquidity Providers: We route asset clearing and liquidity operations through licensed entities, including Quidax.
- Payment Processors: Local currency payout rails are facilitated through secured transaction processors, including Paystack.
- Regulatory Bodies: When legally required, we disclose information to financial regulators and law enforcement agencies.
5. Security & Retention
We implement institutional-grade physical, technical, and administrative security measures to protect your data. We retain your personal data only as long as necessary to fulfill legal, regulatory, or business requirements.
6. Contact Us
If you have any questions regarding this Privacy Policy or your data rights, please contact our Compliance Officer at compliance@qugo.app.