LegalTERMSPRIVACYCOOKIESCOMPLIANCEACCEPTABLE USESECURITYREFUNDSPAYMENT SERVICESFINANCIAL SERVICESV3 · EFFECTIVE 1 AUG 2026Privacy Policy
Drafted against NDPR (Nigeria), PIPEDA (Canada) and GDPR principles · Data Protection Officer: [email protected]
WHAT WE HOLD, PER PRODUCT · AND WHY
| Product | Data | Lawful basis |
|---|---|---|
| Bolrach ID | name (first/middle/last), sex, date of birth, email, phone, verification result | contract · legal obligation (KYC) |
| Payments | transactions, payout accounts, device signals for fraud | contract · legal obligation (AML) · legitimate interest (fraud) |
| Mail / Workspace | your content — never scanned, never profiled | contract only |
| Sites / Store / Stream | your published content, buyer records you control | contract · you act as controller for your buyers |
| Analytics | first-party events, joined only after sign-in or payment | legitimate interest · consent where required |
| Ads | contextual serving data · no cross-site profiles, ever | legitimate interest |
RETENTION · REAL CLOCKS
| Transaction and ledger records | 7 years · financial-records law |
| KYC files | 5 years after relationship ends · AML law |
| Mail and files you delete | 30-day recovery window, then gone |
| Guard event detail | 90 days, then aggregates only |
| Closed-account data | export offered, then minimised to legal holds only |
YOUR RIGHTS · AS BUTTONS, NOT PARAGRAPHS
Export everything we hold on youCorrect my detailsDelete what the law lets us deleteObject to a legitimate-interest use
Each request is acknowledged with a case number and answered within 30 days. Escalation: [email protected], then your data-protection authority.
THE COMMITMENTS THAT DO THE WORK
✓ We do not sell personal data. There is no price at which this changes.
✓ Mail and files are never scanned for advertising or AI training.
✓ Bolrach AI acts on your data only when you invoke it, and its runs are logged to you.
✓ Cross-border transfers use recognised safeguards, listed in the annex with the receiving country.
✓ Processors are listed publicly by category, updated before any change takes effect.
Business customers: the Data Processing Addendum for your own buyers' data signs electronically from your console settings, and versions itself like everything else.