1. Information We Collect
To provide robust financial settlements, mobile agency banking, and hardware POS operations, 9iceMoney collects specifically defined data categories governed by CBN regulations and NDPA mandates.
- Legal full name, DOB, gender
- Bank Verification Number (BVN) validation
- National Identification Number (NIN) hash
- Residential / Kiosk GPS physical address
- Virtual settlement account details
- Transaction Reference Numbers (RRN/STAN)
- Aggregated wallet float balance & histories
- Utility bills & token recharge records
- POS terminal serial number & firmware version
- Cellular SIM IMSI / IMEI anti-fraud pairing
- Kiosk geofence verification markers
- Tamper sensor logs & diagnostic data
- IP address & ISP network carrier
- Device OS architecture & build fingerprint
- App session token lifecycles
- Biometric unlock challenge response tokens
2. Lawful Basis for Processing
Under Section 25 of the Nigeria Data Protection Act (NDPA 2023), 9iceMoney processes user information solely under validated lawful grounds:
Processing required to maintain your digital wallet, route card authorizations through NIBSS, remit agency commission floats, and dispatch physical POS replacement hardware.
Fulfilling directives of the Central Bank of Nigeria (CBN), Money Laundering (Prevention and Prohibition) Act 2022, and reporting to the Nigerian Financial Intelligence Unit (NFIU).
Defending the agency platform against unauthorized chargebacks, botnet exploits, SIM-swap attacks, hardware physical tampering, and illicit float diversion.
3. BVN & NIN Verification Protocols
Your Bank Verification Number (BVN) and National Identity Number (NIN) are used exclusively to confirm that you are the authentic account creator through CBN and NIMC sanctioned verification rails.
Full Name, Date of Birth, Registered Phone Number, and verified photograph matched against identity databases.
We never see or access your other commercial bank balances, external account login credentials, or external ATM debit card PINs.
4. Smart POS & Terminal Data Security
9iceMoney operates thousands of Smart POS Android devices across agency networks. Every terminal is hardened against physical, acoustic, and cryptographic tampering.
If physical intrusion of the POS outer shell is detected, the cryptographic keys stored inside the processor's battery-backed memory instantly trigger a self-destruct wipe. Customer card PIN entries are encrypted immediately at the physical keypad level using DUKPT algorithms.
5. Data Storage, Retention & Cloud Security
Customer telemetry and transaction balances are hosted on Tier-4 sovereign enterprise cloud infrastructure adhering to strict statutory retention rules:
| Data Classification | Retention Period | Regulatory Basis | Encryption |
|---|---|---|---|
| Financial Ledger Logs | 5 Years post-settlement | MLPA 2022 / CBN Code | AES-256 |
| Identity Records (BVN/NIN) | Relationship duration + 5 yrs | CBN KYC Directive | Encrypted Hash |
| POS Diagnostic Telemetry | 90 Days rolling window | Internal Standard | TLS 1.3 Transport |
6. Third-Party Sharing & Payment Rails
To power sub-second settlement and instant bill vending, 9iceMoney integrates with strictly authorized financial and government infrastructure partners, including NIBSS (Instant Payments), licensed switching companies, and CBN-licensed tier-1 custodial banks.
7. Your Privacy Rights Under NDPA 2023
As a 9iceMoney customer or POS merchant, you hold comprehensive rights enshrined under Nigerian law, including Right to Access, Right to Rectify, Right to Erasure, Data Portability, and Right to Object.
Submit an authenticated request directly to our regulatory team.
8. Security Incident Response & Contact DPO
9iceMoney operates a continuous Security Operations Center (SOC). In accordance with NDPA guidelines, any confirmed high-risk security breach will be communicated to affected users within 72 hours.
Data Protection Office Address: 9iceMoney Technologies Limited, No 2 Unguwa Uku, Tarauni LGA, Kano, Nigeria. Email: dpo@9icemoney.com