Privacy Policy

Fleepstash respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how personal information is collected, used, stored, shared, and protected when you access or use the Fleepstash website, mobile applications, and related services (collectively, the “Platform”).

Fleepstash is owned by TGR TECH SERVICES LIMITED, a company registered in Nigeria (“TGR Tech”).

The Platform’s software and technical infrastructure are developed and maintained by FLEEPSTACH TECH SERVICE LIMITED, a separate company registered in Nigeria (“FleepStach Tech”).

TGR Tech and FleepStach Tech are separate legal entities.

TGR Tech owns Fleepstash, operates the Platform, and contracts with customers.

FleepStach Tech provides software development, maintenance, technical infrastructure, and related technology services.

Fleepstash may use independent financial institutions and payment service providers to support payment and money transfer services.

This Privacy Policy explains how personal information is handled in connection with these activities.

By using Fleepstash, you acknowledge that your personal information may be processed as described in this Privacy Policy and in accordance with applicable data protection law.

2.1 TGR TECH SERVICES LIMITED

TGR TECH SERVICES LIMITED owns Fleepstash and is responsible for operating the Platform and contracting with customers.

TGR Tech determines the purposes for which personal information is collected and used in connection with the services it operates.

For these activities, TGR Tech acts as the data controller, subject to applicable law and the actual processing arrangements.

Company

TGR TECH SERVICES LIMITED

Role

Platform owner and customer contracting company

Country of registration

Nigeria

Website

fleepstash.com

2.2 FLEEPSTACH TECH SERVICE LIMITED

FLEEPSTACH TECH SERVICE LIMITED develops and maintains the software and technical infrastructure used by Fleepstash.

It may process personal information on behalf of TGR Tech where necessary to provide software development, maintenance, hosting, security, troubleshooting, and related technical services.

Where it processes information on behalf of TGR Tech, it acts as a data processor under appropriate contractual arrangements.

Its actual role will depend on the activities it performs. If it independently determines the purposes and means of processing particular personal information, its responsibilities will be assessed separately.

2.3 Independent Financial Service Providers

Fleepstash may use independent financial institutions and payment service providers to support payment, money transfer, currency conversion, and other financial services.

These providers may collect and process personal information under their own legal obligations and service arrangements.

Where a provider independently determines how personal information is processed for its financial services, it may act as a separate data controller.

We will explain the relevant provider’s role where required by law.

The information we collect depends on the services you use, the country in which you access the Platform, and the requirements of the relevant service.

3.1 Identity and Account Information

When you create an account, we may collect:

• Full name.
• Date of birth.
• Email address.
• Telephone number.
• Country of residence.
• Residential address, where required.
• Account username and other account identifiers.
• Account registration and verification status.

We use this information to create and manage your account, verify your identity where required, communicate with you, and provide the Platform.

3.2 Identity Verification Information

Where identity verification is required, we or the relevant verification service may collect:

• Government issued identification details.
• Passport or national identity information.
• Identification document images.
• Photograph or selfie.
• Verification results.
• Address verification information.
• Information required to assess whether an identity document is valid.
• Additional information required for compliance checks.

The exact information collected will depend on the verification method and the requirements of the relevant service.

We will not require every customer to provide every category of information where it is not necessary for the service.

3.3 Financial and Transaction Information

When you use payment or money transfer services, we may collect:

• Transaction amounts.
• Transaction currencies.
• Exchange rates.
• Payment method.
• Recipient details.
• Sender details.
• Transaction reference numbers.
• Payment status.
• Transfer destination.
• Transaction dates and times.
• Fees and charges.
• Refund and reversal information.
• Information about failed, delayed, or disputed transactions.

Where required for a service, we may also collect information about the source or purpose of funds and other transaction related details.

We do not claim to hold customer funds merely because transaction information appears in the Platform.

3.4 Technical and Device Information

When you use the Platform, we may collect technical information such as:

• Device type.
• Operating system.
• Application version.
• IP address.
• Browser information.
• Device identifiers.
• Network information.
• Login timestamps.
• Application activity.
• Error reports.
• Crash reports.
• Security events.

We use this information to maintain the Platform, diagnose technical problems, protect accounts, and improve security.

3.5 Customer Support Information

When you contact us, we may collect:

• Your name.
• Contact information.
• Account identifier.
• Transaction reference.
• The content of your message.
• Documents or information you provide to explain an issue.
• Our support communications and resolution records.

We use this information to respond to your request, investigate complaints, and maintain records of customer support activities.

3.6 Website Information and Cookies

When you visit our website, we may collect information about your browser, device, and interactions with the website.

We may use cookies or similar technologies to:

• Keep the website functioning.
• Maintain security.
• Remember necessary preferences.
• Understand website performance.
• Measure usage where permitted.

Where non essential cookies or similar technologies require consent, we will provide an appropriate choice mechanism.

You may manage cookies through your browser settings. Disabling certain cookies may affect website functionality.

3.7 Information We Receive from Other Sources

We may receive personal information from:

• Financial institutions.
• Payment service providers.
• Identity verification services.
• Fraud prevention services.
• Technical service providers.
• Other parties involved in a transaction.
• Public or official sources where legally permitted.

We use such information only where it is necessary for the relevant service, security, compliance, or other lawful purpose.

We use personal information for the following purposes.

4.1 Account Registration and Management

We use your information to:

• Create your account.
• Verify your contact details.
• Maintain account records.
• Manage account access.
• Provide customer support.
• Communicate important account information.

4.2 Identity Verification and Compliance

We may use personal information to:

• Verify your identity.
• Confirm eligibility for a service.
• Meet applicable legal requirements.
• Support required financial service checks.
• Prevent fraud and misuse.
• Investigate suspicious activity.
• Respond to lawful requests from competent authorities.

4.3 Payment and Transaction Processing

We use transaction information to:

• Receive and process your instructions.
• Communicate with relevant financial service providers.
• Display transaction information.
• Track transaction status.
• Investigate failed or delayed transactions.
• Support refunds, reversals, and disputes.
• Maintain transaction records.

The relevant financial service provider may independently process information necessary to provide its services.

4.4 Security and Fraud Prevention

We may use personal information and technical information to:

• Detect suspicious account activity.
• Protect the Platform from unauthorised access.
• Identify potential fraud.
• Investigate security incidents.
• Prevent misuse.
• Protect customers and service providers.

Where permitted by law, we may share relevant information with service providers or competent authorities to support these activities.

4.5 Platform Maintenance and Improvement

We may use technical information and limited usage information to:

• Identify application errors.
• Diagnose crashes.
• Improve performance.
• Maintain infrastructure.
• Understand technical issues.
• Test and improve Platform functionality.

Where possible, we will use aggregated or de identified information for analytics and product improvement.

4.6 Customer Communications

We may use your contact information to send:

• Account notifications.
• Verification messages.
• Transaction updates.
• Security alerts.
• Customer support responses.
• Important service announcements.
• Changes to our Terms or Privacy Policy.

Where required, we will obtain consent before sending marketing communications.

You may withdraw consent for optional marketing communications without affecting necessary service or security messages.

4.7 Legal Claims and Dispute Resolution

We may process personal information where necessary to:

• Investigate complaints.
• Resolve disputes.
• Establish or defend legal claims.
• Maintain required records.
• Respond to lawful requests.
• Protect our rights and the rights of others.

We process personal information only where an applicable lawful basis permits us to do so.

Depending on the activity, these bases may include:

The lawful basis will depend on the specific information and purpose.

Where processing relies on consent, you may withdraw your consent. Withdrawal does not affect processing that took place lawfully before withdrawal or processing that has another valid legal basis.

We do not sell your personal information to advertisers.

We may share personal information with the following categories of recipients where necessary and lawful.

6.1 Financial Institutions and Payment Service Providers

We may share information with financial institutions, payment service providers, and other providers involved in processing transactions.

This may include identity information, transaction details, recipient information, payment references, and compliance information.

These providers use the information according to their own responsibilities and applicable legal requirements.

6.2 Identity Verification Services

We may share identity information and verification documents with services that help us verify customer identity, address, or other required information.

These services may process information to perform verification, detect document fraud, and return verification results.

6.3 Technology and Infrastructure Services

We may share information with services that support:

• Cloud hosting.
• Database infrastructure.
• Application hosting.
• Software maintenance.
• Security monitoring.
• Error reporting.
• Technical support.
• Data storage.

FleepStach Tech may access or process information as necessary to provide its technical services.

6.4 Fraud Prevention and Security Services

We may share information with services that help detect fraud, protect accounts, assess suspicious activity, and maintain security.

6.5 Professional Advisers

We may share information with lawyers, auditors, accountants, consultants, and other professional advisers where necessary and permitted by law.

6.6 Competent Authorities

We may disclose personal information to courts, regulators, law enforcement agencies, or other competent authorities where required or permitted by law.

6.7 Business Transfers

If TGR Tech or the relevant Fleepstash business undergoes a merger, acquisition, restructuring, or other business transfer, personal information may be transferred as part of that transaction where permitted by law.

We will take appropriate steps to protect personal information during such transfers.

Fleepstash is associated with companies registered in Nigeria and may use services located in other countries.

Your personal information may therefore be processed or stored outside your country of residence.

International transfers may occur when:

• A financial service provider operates in another country.
• A cloud service stores information in another country.
• An identity verification service processes documents outside Nigeria.
• A technical service supports the Platform from another location.
• A transaction involves more than one country.

Where personal information is transferred internationally, we will take steps required by applicable law to ensure that the transfer is lawful and that appropriate safeguards are in place.

Depending on the applicable legal requirements, these safeguards may include contractual protections, recognised transfer mechanisms, adequacy arrangements, or other lawful measures.

We will provide information about relevant international transfers where required.

We retain personal information only for as long as necessary for the purposes described in this Privacy Policy, subject to applicable legal requirements.

Retention periods may depend on:

• The type of information.
• The purpose for which it was collected.
• Whether your account remains active.
• Transaction and financial recordkeeping requirements.
• Identity verification requirements.
• Fraud prevention and security needs.
• Legal claims and dispute resolution.
• Applicable retention obligations.

Account information may be retained while your account is active and for a reasonable period after closure where necessary.

Transaction and compliance records may need to be retained after account closure to meet applicable legal obligations or resolve disputes.

Technical logs may be retained for the period reasonably necessary for security, troubleshooting, and operational purposes.

We will review retention practices and take reasonable steps to delete or anonymise information when it is no longer required, unless continued retention is permitted or required by law.

We take reasonable technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss, or destruction.

These measures may include:

• Access controls.
• Authentication mechanisms.
• Encryption where appropriate.
• Secure data transmission.
• Monitoring of security events.
• Software updates.
• Restricted access to personal information.
• Security reviews.
• Backup and recovery procedures.
• Staff and service provider confidentiality obligations.

Access to personal information is limited to people and services that need it for their responsibilities.

No method of transmission, storage, or processing can be guaranteed to be completely secure.

We will respond to suspected personal data breaches in accordance with applicable law, including any notification requirements that apply.

Depending on applicable law and the circumstances of processing, you may have rights concerning your personal information.

10.1 Right to Information

You may request information about how your personal information is collected, used, stored, and shared.

10.2 Right of Access

You may request access to personal information we hold about you, subject to applicable legal restrictions.

10.3 Right to Rectification

You may request correction of inaccurate or incomplete personal information.

10.4 Right to Object

You may object to certain processing activities where the law provides this right.

10.5 Right to Restrict Processing

You may request restriction of processing in circumstances provided by applicable law.

10.6 Right to Data Portability

Where applicable, you may request a copy of personal information in a commonly used format or request that it be transferred to another organisation.

10.7 Right to Erasure

You may request deletion of personal information where applicable law provides this right.

We may need to retain certain information to comply with legal obligations, resolve disputes, protect security, or establish or defend legal claims.

10.8 Right to Withdraw Consent

Where processing relies on consent, you may withdraw that consent.

Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

10.9 Rights Relating to Automated Decisions

Where applicable, you may have rights concerning decisions made solely through automated processing that produce legal or similarly significant effects.

We will handle such requests in accordance with applicable law.

You may submit a privacy request through the contact options available on our website.

Email hello@fleepstash.com or visit fleepstash.com.

Please include enough information for us to identify your request and verify your identity where necessary.

We may request additional information where reasonably necessary to protect your personal information from unauthorised disclosure.

We will respond within the time required by applicable law.

Where we cannot fulfil a request, we will explain the reason where legally permitted.

You may also have the right to lodge a complaint with the Nigeria Data Protection Commission or another competent data protection authority.

Our website may use cookies and similar technologies to support functionality, security, and performance.

Cookies may be used to:

• Maintain necessary website functionality.
• Remember preferences.
• Support security.
• Measure website performance.
• Understand usage where permitted.

We will provide appropriate information and choices for cookies where required by law.

You can manage cookies through your browser settings.

Some cookies are necessary for the website to function. Disabling them may affect your ability to use certain features.

Fleepstash is intended for individuals who meet the minimum age requirements specified in our Terms and Conditions.

We do not knowingly collect personal information from individuals who are not eligible to use the Platform.

If we become aware that personal information has been collected from an ineligible individual in circumstances where it should not have been collected, we will take appropriate steps in accordance with applicable law.

The Platform may contain links to external websites, applications, or services.

Those services may have their own privacy policies and practices.

This Privacy Policy does not govern information collected directly by external services outside our control.

We encourage you to review the privacy information provided by relevant services before using them.

We may update this Privacy Policy to reflect changes in:

• Our services.
• Our company structure.
• Financial service arrangements.
• Technology and infrastructure.
• Data processing practices.
• Applicable laws or regulatory requirements.

We will publish the updated Privacy Policy on the Platform and provide notice of material changes where required by law.

The updated version will state its effective date.

Where applicable law requires consent for a change in processing, we will obtain the necessary consent.

For questions about this Privacy Policy or requests concerning your personal information, contact TGR TECH SERVICES LIMITED using the details below.

Email

hello@fleepstash.com

Registered office

No 6, Road 1, Lekki County Homes
Ikota, Lagos, Nigeria

Website

fleepstash.com

For privacy requests relating to personal information processed through Fleepstash, contact TGR Tech through the Platform.

If you believe that your personal information has been processed in violation of applicable data protection law, you may have the right to lodge a complaint with the relevant data protection authority.

For Nigeria, the relevant authority is:

Nigeria Data Protection Commission (NDPC)
ndpc.gov.ng

You may also contact another competent data protection authority where applicable to your circumstances.

This Privacy Policy is intended to be interpreted in accordance with applicable data protection laws, including the Nigeria Data Protection Act 2023 and relevant regulations or directives.

Where mandatory data protection laws apply in another country in which Fleepstash operates or provides services, those laws will also apply to the relevant processing activities.

Nothing in this Privacy Policy removes or limits any privacy rights available to you under applicable law.