Revolutra - Smart Investment Solutions

1. Introduction

REVOLUTRA ("we", "us", "our") is committed to protecting the privacy of users of our website and investment platform (the "Platform"). This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights you have over it, in line with the Nigeria Data Protection Act (NDPA) 2023.

2. Data Controller

REVOLUTRA is the data controller responsible for your personal data. Our Data Protection Officer (DPO) can be reached at support@revolutra.com.

3. Information We Collect

Category	Examples
Identity data	Full name, date of birth, NIN, BVN, government-issued ID, photograph/selfie for verification
Contact data	Email address, phone number, residential address
Financial data	Bank account details, transaction history, investment amounts, source-of-funds declarations
Technical data	IP address, device identifiers, browser type, log data, cookies
Usage data	Pages visited, features used, time spent on the Platform
Communications	Support requests, survey responses, correspondence with us

We collect this data directly from you (e.g., during registration or KYC), automatically through your use of the Platform, and occasionally from third parties such as identity verification providers or credit reference agencies.

4. How We Use Your Information

To create and manage your account;
To verify your identity and comply with KYC/AML obligations;
To process investments, transactions, and withdrawals;
To communicate with you about your account, transactions, or changes to our services;
To detect and prevent fraud, unauthorized access, and other illegal activity;
To improve the Platform, including analytics and troubleshooting;
To comply with legal and regulatory obligations, including reporting to relevant financial authorities where required;
To send marketing communications, where you have consented (you may opt out at any time).

5. Legal Basis for Processing

Under the NDPA, we rely on one or more of the following legal bases to process your personal data:

Contractual necessity — to provide the services you've signed up for;
Legal obligation — to comply with AML, tax, and financial regulatory requirements;
Consent — for optional activities such as marketing communications;
Legitimate interest — for fraud prevention, security, and Platform improvement, balanced against your rights.

6. How We Share Information

We do not sell your personal data. We may share it with:

Regulators and law enforcement, where legally required;
Identity verification and KYC service providers;
Payment processors and banking partners to facilitate transactions;
Cloud hosting and IT service providers, under confidentiality obligations;
Professional advisors (auditors, lawyers) where necessary;
A successor entity in the event of a merger, acquisition, or restructuring, with notice to you.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to keep you logged in, remember your preferences, and understand how the Platform is used. You can control cookies through your browser settings; disabling certain cookies may affect Platform functionality.

8. Data Retention

We retain personal data for as long as necessary to provide our services and to comply with legal, tax, and regulatory recordkeeping requirements — typically a minimum of 5 years after account closure for financial and KYC records, or longer where required by law. When no longer needed, data is securely deleted or anonymized.

9. Data Security

We implement technical and organizational measures — including encryption, access controls, and regular security reviews — to protect your data against unauthorized access, loss, or misuse. No system is completely secure, and we encourage you to also protect your account credentials.

10. International Data Transfers

Where we transfer your data outside Nigeria (for example, to a cloud provider with servers abroad), we ensure the destination country provides an adequate level of data protection, or we implement appropriate safeguards, as required under the NDPA.

11. Your Rights

Under the NDPA, you have the right to:

Access the personal data we hold about you;
Request correction of inaccurate or incomplete data;
Request deletion of your data, subject to our legal retention obligations;
Object to or restrict certain types of processing;
Withdraw consent at any time, where processing is based on consent;
Request a portable copy of your data in a structured format;
Lodge a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise any of these rights, contact us using the details in Section 14.

12. Children's Privacy

The Platform is not directed at individuals under 18. We do not knowingly collect personal data from minors. If we learn we have inadvertently done so, we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via the Platform or by email before they take effect. The "Last updated" date at the top reflects the most recent revision.

14. Contact Us & Complaints

For questions, requests, or complaints about how we handle your personal data, contact:

REVOLUTRA — Data Protection Officer
Website: revolutra.com
Email: support@revolutra.com
Phone: 07014022890

You may also lodge a complaint directly with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

Privacy Policy

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