Who We Are

ResolveX Technologies is the data controller responsible for your personal data collected through the Platform. We are a technology company incorporated in the Federal Republic of Nigeria, operating the ResolveX financial dispute management platform.

We are committed to handling your data transparently, fairly, and lawfully in accordance with:

What Personal Data We Collect

Information You Provide Directly

• Registration Information: Full name, email address, phone number, and password when you create an account.
• Financial Information: Bank name, branch name, account name, and account number provided when lodging a complaint. We do not collect or store card numbers, BVN, or PINs.
• Complaint Information: Dispute type, description of the issue, amount in dispute, and supporting documents (screenshots, receipts, bank alerts) uploaded as evidence.
• Communication Data: Messages exchanged between you and bank staff through the in-ticket messaging feature.
• Booking Information: Appointment date, time, and branch selected when booking a physical session.
• Profile Information: Any updates you make to your account profile, including notification preferences.

Information Collected Automatically

• Usage Data: Pages visited, features used, time spent on the platform, click patterns, and interaction logs.
• Device & Technical Data: IP address, device type, operating system, browser type and version, and mobile network information.
• Log Data: System logs including login timestamps, complaint submission timestamps, and session activity records.
• Cookie Data: Data collected through cookies and similar technologies. See our Cookie Policy for full details.

How We Use Your Personal Data

We use your personal data only for the purposes described below:

• Account Management: To create, maintain, and secure your account on the Platform.
• Complaint Processing: To receive your complaint, assign it to the correct Partner Bank and branch, and facilitate its resolution.
• Communication: To send you notifications about your complaint status, appointment confirmations, and important platform updates.
• Session Booking: To manage your physical appointment bookings and generate your QR-coded VIP Pass.
• Platform Improvement: To analyse usage patterns (in aggregate, anonymised form) to improve the Platform's functionality and user experience.
• Legal Compliance: To maintain records required by Nigerian law, comply with lawful regulatory requests, and respond to valid legal processes.
• Security: To detect, prevent, and investigate fraud, unauthorised access, and other harmful activities.
• Customer Support: To respond to your enquiries and assist you with any issues regarding the Platform.

We will never use your data for unsolicited marketing, profiling for third-party advertising, or any purpose incompatible with the purposes stated above.

Legal Basis for Processing

Under the Nigeria Data Protection Act 2023, we must have a lawful basis for processing your personal data. We rely on the following legal bases:

• Contractual Necessity: Processing required to provide you with the services you have signed up for — primarily complaint submission, tracking, and booking.
• Legitimate Interests: Processing necessary for our legitimate business interests, such as platform security, fraud prevention, and service improvement — provided these interests do not override your rights.
• Legal Obligation: Processing required to comply with Nigerian law, including CBN reporting requirements and responses to lawful regulatory requests.
• Consent: Where we rely on your consent (such as for optional communications), you may withdraw that consent at any time by contacting us or updating your notification preferences.

How We Share Your Data

We do not sell, rent, or trade your personal data. We share your data only in the following circumstances:

With Partner Banks

When you submit a complaint against a bank, we share the relevant complaint details (including your name, contact information, account details, complaint description, and supporting evidence) with the relevant Partner Bank. This is the core function of the Platform and is necessary to process your complaint.

With Regulatory Bodies

Where required or permitted by law, we may share complaint data with the Central Bank of Nigeria (CBN) or the Federal Competition and Consumer Protection Commission (FCCPC) in connection with escalated complaints or regulatory inquiries.

With Service Providers

We use carefully selected third-party service providers to help operate the Platform (including cloud hosting, email delivery, and analytics services). These providers only process your data on our instructions and are contractually prohibited from using it for any other purpose.

For Legal Compliance

We may disclose your data where required by law, court order, or where we believe disclosure is necessary to protect the rights, property, or safety of ResolveX, our users, or the public.

Data Retention

We retain your personal data for as long as is necessary for the purposes described in this policy, subject to the following principles:

• Active Accounts: Data is retained for as long as your account remains active.
• Complaint Records: Closed complaint tickets are retained for a minimum of 5 years following resolution. This period is required to maintain audit trails for regulatory compliance purposes and to support any future legal proceedings.
• Inactive Accounts: If your account has been inactive for 3 consecutive years, we will notify you before deleting your data.
• Deleted Accounts: Upon account deletion, we will remove your personal data within 90 days, except where retention is required by law.
• Legal Requirements: Certain data may be retained for longer periods where required by Nigerian law or a lawful regulatory order.

How We Protect Your Data

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS (Transport Layer Security);
• Encryption of sensitive data at rest;
• Strict access controls ensuring only authorised personnel can access personal data;
• Regular security testing and vulnerability assessments;
• Audit logging of all access to personal data;
• Staff training on data protection obligations;
• Incident response procedures in the event of a data breach.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the Nigeria Data Protection Commission (NDPC) in accordance with the timelines prescribed by the NDPA 2023.

Your Privacy Rights

Under the Nigeria Data Protection Act 2023, you have the following rights regarding your personal data:

To exercise any of these rights, please contact us at info@useresolvex.com. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us immediately at info@useresolvex.com and we will take prompt steps to delete such data.

Third-Party Links

The Platform may contain links to third-party websites or services. This Privacy Policy applies only to the ResolveX Platform. We are not responsible for the privacy practices of any third-party websites, and we encourage you to review the privacy policies of any external sites you visit.

Cross-Border Data Transfers

Where we use third-party service providers (such as cloud hosting) whose infrastructure may be located outside Nigeria, we ensure that appropriate safeguards are in place to protect your data, including contractual clauses that require overseas processors to maintain data protection standards equivalent to those required by the NDPA 2023.

Your data will only be transferred outside Nigeria where necessary for service delivery and subject to adequate protections.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. When we make material changes, we will update the "Last Updated" date at the top of this page and notify you by email or a prominent notice on the Platform.

We encourage you to review this policy periodically. Your continued use of the Platform after any changes constitutes acceptance of the updated policy.

Contact Us & Data Protection Officer

For all privacy-related enquiries, requests to exercise your rights, or concerns about how we handle your data, please contact us:

• Email: info@useresolvex.com
• Subject line: "Privacy Request" or "Data Protection Enquiry"
• Website: useresolvex.com
• Company: ResolveX Technologies, Federal Republic of Nigeria

If you are unsatisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpb.gov.ng.