Article 4.1: Data Retention Policy
Zelencio adheres to a strict data retention schedule governed by international financial regulations and Anti-Money Laundering (AML) standards.
4.1.1. Active Accounts: We retain your personal and transactional data for as long as your account remains active to provide the requested services.
4.1.2. Statutory Retention (The 5-Year Rule): In accordance with global Virtual Asset Service Provider (VASP) mandates and local laws (such as the Nigerian Money Laundering Prevention and Prohibition Act), Zelencio is legally required to retain your KYC identity data, biometric verification logs, and full transaction history for a period of no less than five (5) years after the closure of your account.
4.1.3. Automated Deletion: Once the statutory retention period has expired, Zelencio utilizes automated protocols to permanently delete or irreversibly anonymize your data from our production and backup servers.
Article 4.2: Your Data Rights and the "Right to be Forgotten"
In compliance with the Nigeria Data Protection Regulation (NDPR) and global privacy standards, you possess the following rights regarding your data:
4.2.1. Right to Access: You may request a summary of the personal data Zelencio holds about you via the "Profile" section of the app or by contacting our Support team.
4.2.2. Right to Rectification: You have the right to correct inaccurate or incomplete data. Note that changing core KYC data (e.g., your legal name) will require a manual review and the submission of updated government documentation.
4.2.3. Right to Account Closure and Deletion: As displayed in the "Security" settings of the Zelencio mobile application, you may initiate an account closure at any time.
The Deletion Process: Upon your request to "Close Account," your profile will be deactivated immediately. You will lose access to all Zelencio services.
Financial Finality: Any remaining balances must be withdrawn before closure. By proceeding with deletion while holding a balance, you provide an explicit "Funds Forfeiture" consent as described in our Terms of Service.
Retention Exception: While your access is deleted, your records are moved to an offline, encrypted archive for the duration of the 5-year statutory period mentioned in Article 4.1.2.
Article 4.3: International and Transborder Data Transfers
Zelencio operates as a high-performance digital ecosystem. To provide 24/7 global service, your data may be processed in jurisdictions outside of your home country.
4.3.1. Technical Infrastructure: Our primary encrypted servers may be located in secure data centers globally.
4.3.2. Data Protection Standard: Regardless of where your data is processed, Zelencio enforces the same high standard of AES-256 encryption and security. We ensure that any third-party processors (such as Cloudinary for media) are contractually bound to provide equivalent privacy protections.
Article 4.4: Children’s Privacy
The Zelencio platform is a financial environment strictly reserved for individuals who have reached the age of majority (18 years or older).
4.4.1. Prohibition: We do not knowingly collect or solicit data from anyone under the age of 18.
4.4.2. Enforcement: Our mandatory KYC and Liveness checks are designed to detect and block access for minors. If we discover that an account has been opened by a minor, it will be terminated immediately.
Article 4.5: Updates to this Privacy Policy
Zelencio reserves the right to update this Privacy Policy to reflect changes in technology or global regulations.
4.5.1. Notification: Significant changes will be announced via in-app notifications or email.
4.5.2. Acceptance: Your continued use of the app after an update is posted constitutes your acknowledgement of the revised practices.
Article 4.6: Contacting the Data Protection Officer (DPO)
If you have specific questions regarding your data, its storage, or your rights, you may contact our dedicated privacy team: