1. Who we are
Pursible is a brand operated by Pursible Technology Limited. Pursible Technology Limited (“Pursible”, “we”, “us”) operates the Pursible app and the website at pursible.com, and is the data controller for the personal data described in this policy.
- Data protection contact: Data Protection Officer, privacy@pursible.com
2. What this policy covers
This policy explains what personal data we collect when you use our website, join our waitlist or use the Pursible app, why we collect it, who we share it with, how long we keep it and the rights you have. It is written to meet the Nigeria Data Protection Act 2023 (the “NDPA”) and the regulations and guidance issued under it.
3. What we collect
We collect only what each stage needs. Pursible uses verification tiers (see Features), so the data we hold depends on how far you have verified.
| When | What we collect |
|---|---|
| Waitlist (website) | Your email address and the time you joined. |
| Creating an account | Your name, email address, password (stored only as a one-way hash) and transaction PIN (stored only as a one-way hash). |
| Tier 1 | Date of birth, home address, phone number (confirmed by a one-time code), your BVN or NIN together with the details the government record returns, such as your name, date of birth and photo, and the result of an automatic watchlist screening. |
| Tier 2 | Both your BVN and NIN, an image of a government-issued photo ID and the result of matching it to your BVN or NIN record, a selfie with the result of comparing it to your ID record (biometric data), a record of your consent to that check (when you gave it, which version of the consent text you saw, and the IP address it came from), and the result of sanctions and politically exposed person screening. |
| Tier 3 | Proof of address (a utility bill, or the result of an address check), your answers to our enhanced due diligence questions (your occupation, source of funds, what you will use the USD account for, and how much you expect to receive each month), the result of an up-to-date anti-money-laundering screening, and a record of approval by our USD account provider. |
| Using the app | Your balances and transactions (amounts, dates, references, and the names and account numbers of senders and recipients), the bank accounts you add for withdrawals, stablecoin wallet addresses, conversion quotes, and messages you send to support. |
| Technical data | IP address, device and browser type, the time of each request, security events such as sign-ins and failed PIN attempts, and, if you allow notifications, a device token for push notifications. |
Your BVN, NIN, selfie and ID images, and biometric comparison results are sensitive. BVN and NIN are encrypted at rest, and only masked versions are ever shown. We do not collect card numbers.
We receive some data from others: identity records from government databases through our verification provider, and details of incoming payments from our payment partners.
4. Why we use it, and our lawful basis
Under section 25 of the NDPA we may only process personal data where we have a lawful basis. Ours are:
| Purpose | Lawful basis |
|---|---|
| Opening and running your account, processing payments, conversions and withdrawals | Contract: we need it to provide the service you asked for. |
| Verifying your identity, screening for money laundering, fraud and sanctions, and keeping records | Legal obligation: anti-money-laundering and know-your-customer laws, and the requirements of our regulated partners. |
| Comparing your selfie with your ID record (biometric data) | Your explicit consent, and legal obligation. Before each selfie check, the app shows you what is collected, why, who carries out the check and how long it is kept, and you tick a box to agree. The check can’t start until you do. |
| Protecting accounts, detecting and investigating misuse, and keeping audit logs | Legitimate interests in keeping you, other users and Pursible safe, and legal obligation. |
| Answering your questions and complaints | Contract and legitimate interests. |
| Telling you when Pursible opens (waitlist) | Your consent, given when you join. You can withdraw it at any time. |
| Sending service messages, such as a code, a receipt or a security alert | Contract and legitimate interests. |
We do not sell your personal data, and we do not use it for third-party advertising.
5. Automated decisions
Some identity checks are automated: if your government record, selfie and screening results all match, your verification can be approved without a person reviewing it. If an automated check doesn't pass, a member of our team reviews it before any decision is final. You can ask for a person to review any automated decision about you, give your point of view and contest it, by emailing our Data Protection Officer at privacy@pursible.com.
6. Who we share it with
We share personal data only with those who need it to provide the service, under written contracts that require them to protect it and use it only on our instructions:
- Identity verification provider: to check your BVN, NIN, selfie, ID document and address, and to screen against sanctions and politically exposed person lists.
- Payment and account partners: regulated institutions in Nigeria that provide your NGN account number and process transfers, withdrawals and conversions.
- Cloud hosting and storage providers: who run our servers, database and private file storage.
- Email and SMS providers: to send you one-time codes, receipts and service messages.
We may also disclose personal data:
- to regulators, law enforcement agencies and courts, where the law requires it;
- to our professional advisers, such as lawyers and auditors, under a duty of confidentiality;
- to a buyer or successor if our business is reorganised or sold, under this policy.
You can ask our Data Protection Officer at privacy@pursible.com for the names of our current service providers.
7. Transfers outside Nigeria
Some of our service providers store data outside Nigeria (for example in the European Union), with appropriate safeguards.
8. How long we keep it
| Data | How long |
|---|---|
| Identity verification records (including selfies and consent records), transaction records and audit logs | For as long as your account is open, then at least 5 years after it closes, as anti-money-laundering law requires, or longer if a regulator, court or investigation requires it. |
| Proof of address | Replaced when you renew it. Old copies are kept with your verification records as above. |
| Support messages | Up to 5 years after your account closes. |
| Technical and security logs not tied to a transaction | Up to 12 months. |
| Waitlist email | Until you ask us to remove it, or 24 months after you joined, whichever comes first. |
When the period ends we delete the data or anonymise it so it can no longer identify you.
9. How we protect it
We use encryption in transit (HTTPS) and at rest for BVN and NIN, private storage for identity documents with short-lived access links, one-way hashing for passwords and PINs, access limited to staff who need it, and audit logs that record staff access to identity documents. If a personal data breach is likely to put your rights at risk, we will tell the Nigeria Data Protection Commission within 72 hours of becoming aware of it, and tell you without undue delay. Read more on our Security page.
10. Your rights
Under the NDPA you have the right to:
- be told how your personal data is used (this policy);
- get a copy of the personal data we hold about you;
- have inaccurate or incomplete data corrected;
- have your data deleted, where we no longer need it and the law doesn't require us to keep it;
- restrict how we use your data while a concern is looked into;
- object to processing based on our legitimate interests;
- receive the data you gave us in a common, machine-readable format, or have it sent to another provider;
- withdraw consent at any time, without affecting processing that already happened;
- not be subject to a decision based solely on automated processing that significantly affects you (see section 5).
To use any of these rights, email our Data Protection Officer at privacy@pursible.com from the address on your account. We may ask you to confirm your identity first. We will reply within 30 days. Some rights are limited by law: for example, we can't delete verification and transaction records we must keep under anti-money-laundering law.
11. Complaints
If you're unhappy with how we have handled your data, please contact our Data Protection Officer at privacy@pursible.com first so we can put it right. You also have the right to complain to the Nigeria Data Protection Commission (ndpc.gov.ng).
12. Cookies and similar technologies
This website sets no cookies and uses no analytics, advertising or other third-party tracking. Its fonts and images are served from our own domain.
The Pursible app uses only essential storage on your device, to keep you signed in and to remember settings such as light or dark mode. It can't work without it, so it doesn't need your consent. We don't use cookies or storage for advertising or cross-site tracking.
13. Children
Pursible is only for people aged 18 or over. We do not knowingly collect data from anyone under 18. If you believe a child has given us their data, contact our Data Protection Officer at privacy@pursible.com and we will delete it.
14. Changes to this policy
We will update this policy when how we use personal data changes. The date at the top shows when it last changed. If a change is significant, we will tell you in the app or by email before it takes effect.
15. Contact us
For anything about this policy or your personal data, email our Data Protection Officer at privacy@pursible.com. For general support, see our Contact page.