EarlyPay.ng

Privacy Policy

1. Introduction

This Privacy Policy explains how EarlyHub Ltd ("EarlyHub," "we," "us," or "our"), the company that owns and operates the EarlyPay platform ("EarlyPay," the "Platform," or the "Service"), collects, uses, discloses, stores, and protects the personal data of individuals who use our website, mobile application, USSD channels, and related services (collectively, the "Services").

EarlyHub Ltd is a company duly incorporated in Nigeria under the Companies and Allied Matters Act (CAMA), with its registered office at:

No. 15, Unguwa Uku Zaria Road, Along Unguwa Uku Motor Park, Kano State, Nigeria.

By creating an account, accessing, or using EarlyPay, you agree to the collection and use of your information as described in this Privacy Policy. If you do not agree with this Policy, please do not use the Services.

This Policy is issued in compliance with the Nigeria Data Protection Act, 2023, the NDPA General Application and Implementation Directive, 2025, the Nigeria Data Protection Commission (NDPC) framework, the Central Bank of Nigeria (CBN) regulations applicable to payment service providers, and the Cybercrimes (Prohibition, Prevention, etc.) Act, as amended.


2. Scope of This Policy

This Policy applies to all personal data processed by EarlyHub Ltd in connection with the EarlyPay Platform, including data collected from:

It does not apply to third-party websites, applications, or services that may be linked to or integrated with EarlyPay but are independently operated (e.g. mobile network operators, DISCOs, cable TV providers, payment gateways). We encourage you to review the privacy policies of those third parties separately.


3. Information We Collect

We collect the following categories of personal data:

3.1 Identity & Contact Information

3.2 Financial & Transaction Information

3.3 Technical & Usage Information

3.4 Communications


4. How We Collect Your Information

We collect personal data through:

  1. Direct provision — when you register an account, complete KYC, make a transaction, or contact support.
  2. Automated means — through cookies, SDKs, and analytics tools when you use our website or app.
  3. Third parties — including identity verification providers, mobile network operators, banks, payment processors (e.g. Remita), and regulatory databases (e.g. NIMC for NIN verification), where lawfully permitted.

5. Legal Basis for Processing

In accordance with Section 25 of the NDPA 2023, we process your personal data only where at least one of the following legal bases applies:


6. How We Use Your Information

We use the information we collect to:

We do not sell your personal data to third parties.


7. Sharing and Disclosure of Information

We may share your personal data with:

We require every third party we share data with to respect the security of your personal data and to treat it in accordance with applicable law.


8. Cross-Border Data Transfer

Where your personal data is transferred outside Nigeria (for example, to a cloud service provider with servers abroad), we will ensure that the transfer complies with the NDPA's cross-border transfer requirements, which may include verifying that the recipient country has an adequate level of data protection, obtaining your explicit consent, or relying on appropriate contractual safeguards approved by the NDPC.


9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. In particular:


10. Cookies and Tracking Technologies

We use cookies, SDKs, and similar technologies to:

You can control cookies through your browser or device settings. Disabling cookies may affect the functionality of some parts of the Platform.


11. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:

While we take reasonable steps to protect your data, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.


12. Your Rights as a Data Subject

Under the NDPA 2023, you have the right to:

To exercise any of these rights, contact us using the details in Section 17. We will respond within the timeframe required by applicable law.


13. Children's Privacy

EarlyPay is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. Where parental or guardian consent is legally required for a data subject who cannot independently consent, we will only process such data with the necessary consent and safeguards. If we become aware that we have inadvertently collected data from a minor without appropriate consent, we will take steps to delete that data.


14. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the NDPC and affected data subjects without undue delay, in accordance with the notification timelines prescribed by the NDPA and GAID.


15. Marketing Communications

Where you have opted in to receive marketing or promotional messages, you may withdraw your consent at any time by using the "unsubscribe" link in our emails, replying "STOP" to SMS messages, or contacting our support team. You will continue to receive essential transactional and security communications (e.g. OTPs, transaction receipts) even after opting out of marketing.


16. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes via email, in-app notice, or by posting the updated Policy on our website with a revised "Last Updated" date. Your continued use of the Services after such changes constitutes acceptance of the updated Policy.


17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at:

EarlyHub Ltd (operators of EarlyPay) Address: No. 15, Unguwa Uku Zaria Road, Along Unguwa Uku Motor Park, Kano State, Nigeria Email: support@earlypay.ng Website: https://earlypay.ng

Data Protection Officer: [Insert DPO Name/Email, if designated]

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


18. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act 2023 and its subsidiary regulations.