Privacy Policy

Welcome to Paeflow. Paeflow ("Paeflow", "we", "our", or "us") is a financial management and payment infrastructure platform owned and operated by SmartIV Hauz Ltd ("SmartIV Hauz"), a company duly incorporated under the laws of the Federal Republic of Nigeria.

Paeflow is designed to help entrepreneurs, creators, freelancers, service providers, and businesses manage payments, invoices, financial records, business operations, analytics, and related services through our web platform, mobile applications, and associated services (collectively referred to as the "Platform").

We are committed to protecting the privacy, confidentiality, and security of your personal information and business data. This Privacy Policy explains how we collect, use, store, disclose, process, and protect information obtained through your use of Paeflow.

By accessing or using Paeflow, you acknowledge that you have read, understood, and accepted the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, you should discontinue use of the Platform.

This Privacy Policy applies to:

• Users of the Paeflow platform
• Business account holders
• Entrepreneurs and creators using Paeflow services
• Authorized representatives of business entities
• Team members invited into business profiles
• Visitors to our websites
• Individuals whose information is processed through our services

This Policy applies regardless of whether you access Paeflow through:

• Web applications
• Mobile applications
• APIs
• Third-party integrations
• Customer support channels
• Email communications
• SMS communications
• WhatsApp communications
• In-app notifications

To provide our services effectively, we collect various categories of information.

3.1 Personal Information — We may collect personal information including:

• Full name
• Email address
• Telephone number
• Date of birth
• Residential address
• National Identification Number (NIN)
• Government-issued identification details
• Profile photographs
• Biometric verification information where required by law
• Usernames and account credentials

3.2 Business Information — Where you operate a business profile, we may collect:

• Business name
• Business registration number
• Corporate Affairs Commission (CAC) information
• Business address
• Tax identification information
• Business ownership information
• Director and beneficial owner information
• Business contact information
• Industry classification
• Supporting corporate documents

3.3 Customer Information — Users may enter information relating to their customers, including:

• Customer names
• Email addresses
• Telephone numbers
• Billing information
• Payment information
• Customer transaction history
• Customer communications

Such information remains under the control of the respective user or business account that provided it.

3.4 Financial and Transaction Information — We may collect information relating to:

• Payment transactions
• Transaction references
• Invoice records
• Revenue records
• Payment status information
• Expense records
• Subscription payments
• Financial analytics
• Business performance metrics
• Financial reports generated through the Platform

Paeflow does not directly store complete payment card details. Payment processing is conducted through licensed third-party payment service providers.

3.5 Verification and Compliance Information — To comply with applicable laws, regulations, fraud prevention requirements, and Know Your Customer (KYC) obligations, we may collect:

• NIN records
• CAC registration certificates
• Utility bills
• Proof of address documents
• Identity verification records
• Selfie verification images
• Tax documents
• Business verification records
• Regulatory compliance information

Failure to provide required verification information may result in restricted access to certain features or suspension of services.

3.6 Technical Information — When you use Paeflow, we may automatically collect:

• IP address
• Device identifiers
• Browser information
• Device type
• Operating system
• Session information
• Access timestamps
• Geographic information derived from IP address
• Application version data
• Network information

3.7 Usage Information — We may collect information regarding how users interact with the Platform, including:

• Pages visited
• Features used
• Clickstream activity
• Login history
• Navigation behavior
• User preferences
• Feature engagement
• Search activities

3.8 Communication Information — Where you contact us or interact with our services, we may collect:

• Customer support messages
• Email communications
• WhatsApp communications
• SMS communications
• In-app support requests
• Feedback submissions
• Survey responses

3.9 Documents Uploaded by Users — Users may upload documents including:

• CAC certificates
• Identification documents
• Utility bills
• Financial statements
• Receipts
• Invoices
• Tax documents
• Supporting business records
• Compliance documentation

These documents may be processed, stored, verified, and analyzed to provide services and satisfy regulatory obligations.

We use cookies, web beacons, tracking technologies, and similar tools to:

• Maintain user sessions
• Improve platform performance
• Remember user preferences
• Enhance security
• Prevent fraud
• Analyze usage patterns
• Improve user experience
• Measure effectiveness of features and communications

Users may modify browser settings to refuse cookies; however, certain platform functionalities may become unavailable or impaired.

We collect information through:

Information You Provide — Information submitted during:

• Registration
• Verification
• Payment creation
• Invoice generation
• Customer management
• Support interactions

Automated Collection — Information collected automatically through:

• Website usage
• Application usage
• Device interactions
• Security systems

Third Parties — Information obtained from:

• Payment service providers
• Verification providers
• Government databases where legally permitted
• CAC verification services
• NIN verification services
• Identity verification providers
• Analytics providers
• Financial service partners

We use information collected through Paeflow for legitimate business, operational, compliance, security, and service-delivery purposes. The purposes for which we may process information include:

6.1 Account Creation and Administration — To:

• Create and manage user accounts
• Authenticate users
• Verify account ownership
• Maintain business profiles
• Manage subscriptions
• Enable platform functionality
• Provide customer support

6.2 Service Delivery — To:

• Generate invoices
• Process payment requests
• Facilitate payment collection
• Monitor transaction activities
• Generate financial reports
• Maintain financial records
• Manage customer databases
• Provide business management tools
• Deliver subscription services

6.3 Business Analytics — To:

• Generate performance dashboards
• Analyze revenue trends
• Monitor business growth metrics
• Provide financial summaries
• Generate business intelligence reports
• Identify operational trends
• Produce analytical insights

6.4 AI and Automated Features — To:

• Generate automated financial summaries
• Categorize expenses
• Generate business insights
• Create forecasting outputs
• Produce recommendations
• Generate alerts and reminders
• Improve platform automation
• Enhance user experience

Additional information regarding AI processing is provided in Section 7 of this Privacy Policy.

6.5 Customer Support — To:

• Respond to inquiries
• Investigate complaints
• Resolve technical issues
• Provide onboarding assistance
• Improve support quality

6.6 Security and Fraud Prevention — To:

• Detect suspicious activities
• Prevent fraud
• Investigate security incidents
• Protect users and businesses
• Monitor platform integrity
• Enforce platform policies
• Prevent unauthorized access

6.7 Legal and Regulatory Compliance — To:

• Comply with applicable laws
• Satisfy regulatory obligations
• Fulfill anti-money laundering requirements
• Conduct identity verification procedures
• Maintain legally required records
• Respond to lawful requests from competent authorities

6.8 Platform Development and Improvement — To:

• Improve existing features
• Develop new products and services
• Enhance system performance
• Improve AI models and analytics systems
• Conduct research and development activities
• Test new functionality

6.9 Communications — To communicate with users regarding:

• Account activity
• Security alerts
• Product updates
• Platform announcements
• Service notifications
• Marketing communications (where permitted)
• Subscription reminders
• Payment notifications
• Verification requests

Communications may be delivered through:

• Email
• SMS
• WhatsApp
• In-app notifications
• Push notifications
• Telephone calls where appropriate

Paeflow incorporates automated systems, artificial intelligence technologies, machine-learning tools, rules-based systems, predictive analytics, and related technologies to improve platform functionality.

7.1 AI-Powered Features — Paeflow may use AI technologies to provide:

• Financial summaries
• Revenue analysis
• Expense categorization
• Cashflow projections
• Forecasting tools
• Business performance insights
• Automated recommendations
• Smart notifications
• Customer behavior insights
• Operational efficiency suggestions
• Financial statement generation
• Audit preparation support
• Data classification and organization

7.2 Third-Party AI Services — To provide certain features, Paeflow may utilize trusted third-party artificial intelligence providers and infrastructure providers. Information processed through such systems may include:

• Transaction information
• Revenue records
• Expense records
• Business performance metrics
• User prompts
• Uploaded data relevant to requested services

We take commercially reasonable measures to ensure that third-party providers maintain appropriate privacy, confidentiality, and security standards.

7.3 Informational Nature of AI Outputs — AI-generated outputs are provided solely for informational, operational, analytical, and business-support purposes. Users acknowledge that:

• AI-generated outputs may contain inaccuracies
• AI-generated content may be incomplete
• Recommendations may not be suitable for every business circumstance
• AI outputs do not constitute professional accounting advice
• AI outputs do not constitute legal advice
• AI outputs do not constitute tax advice
• AI outputs do not constitute investment advice
• Users remain solely responsible for business decisions and financial decisions

7.4 Continuous Learning and Improvement — Paeflow may use anonymized and aggregated usage information to:

• Improve algorithms
• Improve prediction accuracy
• Enhance automation systems
• Develop future AI capabilities
• Improve overall platform performance

Paeflow will not use personally identifiable information for model training beyond what is necessary to provide services, unless otherwise permitted by applicable law or user consent.

We do not sell personal information. However, we may disclose information under the circumstances described below.

8.1 Service Providers — We may share information with trusted service providers assisting with:

• Cloud hosting
• Data storage
• Payment processing
• Customer support
• Messaging services
• Analytics services
• Identity verification
• Security monitoring
• AI processing
• Business intelligence services

Such providers are permitted to access information only to the extent necessary to perform services on our behalf.

8.2 Payment Processing Partners — Payment-related information may be shared with licensed payment service providers and financial partners for purposes including:

• Payment processing
• Settlement
• Transaction verification
• Fraud prevention
• Regulatory compliance

Such providers operate under their own privacy policies and regulatory obligations.

8.3 Verification Partners — Information may be shared with identity verification and business verification providers for:

• KYC verification
• Identity authentication
• Business registration verification
• Compliance screening

8.4 Business Profile Users — Where multiple authorized users operate under a single business profile, certain information may be visible to authorized team members according to assigned permissions. Users are responsible for managing permissions granted within their business profiles.

8.5 Legal Requirements — We may disclose information where required by law or where we reasonably believe disclosure is necessary to:

• Comply with legal obligations
• Respond to court orders
• Respond to government requests
• Cooperate with regulatory authorities
• Enforce legal rights
• Protect users
• Investigate fraud
• Prevent illegal activities

8.6 Corporate Transactions — In connection with:

• Mergers
• Acquisitions
• Investments
• Corporate restructuring
• Asset sales
• Financing transactions

Information may be disclosed to relevant parties subject to appropriate confidentiality obligations.

8.7 Aggregated and Anonymized Information — We may use and disclose aggregated, anonymized, statistical, and non-identifiable information for:

• Research
• Reporting
• Product development
• Industry benchmarking
• Marketing
• Business analytics

Such information cannot reasonably be used to identify individual users.

Paeflow serves users in Nigeria and may serve users internationally. As a result, information may be processed, stored, transferred, or accessed in jurisdictions outside a user's country of residence. These jurisdictions may include locations where:

• Cloud providers operate
• Infrastructure providers operate
• AI service providers operate
• Verification providers operate
• Support services operate

Where international transfers occur, Paeflow will implement reasonable safeguards designed to protect personal information consistent with applicable laws and industry standards.

We retain information only for as long as necessary to:

• Provide services
• Comply with legal obligations
• Resolve disputes
• Prevent fraud
• Enforce agreements
• Maintain business records
• Support legitimate business operations

Retention periods may vary depending on:

• Type of information
• Legal requirements
• Regulatory obligations
• Security considerations
• Business necessity

Even after account closure, certain information may be retained where required by law or necessary for fraud prevention, dispute resolution, auditing, tax compliance, or regulatory purposes.

Subject to applicable laws and regulatory requirements, users may have certain rights regarding their personal information. These rights may include:

11.1 Right of Access — Users may request confirmation regarding whether Paeflow processes their personal information and may request access to information held about them.

11.2 Right to Correction — Users may request correction of inaccurate, incomplete, or outdated information maintained by Paeflow. Users are encouraged to keep account information accurate and current.

11.3 Right to Deletion — Users may request deletion of personal information in certain circumstances. However, Paeflow may retain information where necessary to:

• Comply with legal obligations
• Meet regulatory requirements
• Prevent fraud
• Resolve disputes
• Enforce agreements
• Maintain financial records
• Protect platform security
• Fulfill legitimate business purposes

11.4 Right to Restrict Processing — Where permitted by law, users may request restriction of certain processing activities. Restriction requests may affect the availability of some platform features and services.

11.5 Right to Withdraw Consent — Where processing is based on consent, users may withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted before withdrawal. Certain services may become unavailable if consent necessary for those services is withdrawn.

11.6 Right to Object — Users may object to certain categories of processing where permitted under applicable law. We will evaluate such requests in accordance with legal and operational obligations.

11.7 Marketing Preferences — Users may opt out of receiving marketing communications by:

• Following unsubscribe instructions
• Adjusting communication preferences within the Platform
• Contacting Paeflow support

Service-related communications may continue even where marketing preferences are disabled.

Users may request a copy of certain information associated with their account in a structured and commonly used format, where technically feasible. Such information may include:

• Profile information
• Business profile information
• Invoice records
• Transaction records
• Expense records
• Customer records
• Financial reports generated through the Platform

Requests may be subject to identity verification and applicable legal limitations.

Users may request deletion of their Paeflow account by contacting support or through functionality provided within the Platform. Upon receiving a deletion request, Paeflow may:

• Deactivate account access
• Remove non-essential information
• Retain information required by law
• Retain records necessary for fraud prevention
• Retain records necessary for dispute resolution
• Retain financial and compliance records where legally required

Deletion of an account does not automatically delete all information where retention is required for legitimate legal, regulatory, or security purposes.

Paeflow permits users to maintain one or more business profiles under a single user account. Each business profile may contain:

• Financial records
• Customer records
• Team members
• Transactions
• Invoices
• Reports
• Analytics
• Verification documents

Paeflow maintains logical separation between business profiles and implements access controls designed to prevent unauthorized access. Users remain responsible for:

• Managing team permissions
• Monitoring authorized access
• Protecting account credentials

Paeflow takes the protection of information seriously and employs commercially reasonable technical, administrative, and organizational safeguards designed to protect information from unauthorized access, misuse, disclosure, alteration, or destruction. Security measures may include:

• Encryption of data in transit
• Encryption of sensitive information at rest where appropriate
• Secure authentication mechanisms
• Access controls
• Monitoring systems
• Security audits
• Intrusion detection measures
• Logging and activity monitoring
• Backup and recovery procedures

While we strive to protect information, no internet-based service, electronic storage system, or transmission method can be guaranteed to be completely secure. Accordingly, Paeflow cannot guarantee absolute security of information. Users are responsible for maintaining the confidentiality of their account credentials and promptly notifying Paeflow of any suspected unauthorized access.

For security, compliance, troubleshooting, and fraud prevention purposes, Paeflow may maintain records relating to:

• Login activities
• Device information
• Session history
• Permission changes
• Transaction activities
• Account modifications
• Administrative actions
• Security events

Such logs may be retained for periods necessary to maintain platform security, investigate incidents, satisfy compliance obligations, and improve service reliability.

Paeflow is intended for use by individuals and business representatives who possess the legal capacity to enter into binding agreements under applicable laws. Paeflow does not knowingly solicit or collect personal information from individuals who do not possess such legal capacity.

If we become aware that information has been collected in violation of applicable legal requirements, we may take steps to delete such information and restrict access to the Platform. Parents, guardians, or responsible parties who believe information has been collected improperly may contact Paeflow using the contact details provided below.

The Platform may contain links to third-party websites, applications, services, integrations, or resources. Paeflow is not responsible for:

• The privacy practices of third parties
• Third-party content
• Third-party security practices
• Third-party terms or policies

Users should review the privacy policies and terms of any third-party service they choose to access.

Paeflow may introduce additional services, products, integrations, and functionality including but not limited to:

• Accounting integrations
• Tax services integrations
• Banking integrations
• Credit and financing services
• Advanced business intelligence services
• Identity verification services
• Regulatory compliance services
• Artificial intelligence enhancements
• Enterprise tools

Where such services involve material changes to information processing practices, Paeflow may update this Privacy Policy and provide notice where required by applicable law.

Paeflow reserves the right to update, amend, revise, or replace this Privacy Policy at any time. Updates may occur due to:

• Changes in applicable laws
• Regulatory requirements
• Product enhancements
• New services
• Security improvements
• Business operations

Updated versions will be posted on the Platform with a revised effective date. Where required by law, users may be notified through:

• Email
• SMS
• WhatsApp
• In-app notifications
• Website notices

Continued use of the Platform after updates become effective constitutes acceptance of the revised Privacy Policy.

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Federal Republic of Nigeria, without regard to conflict-of-law principles. Nothing in this Privacy Policy limits any rights that may be available to users under applicable data protection laws and regulations.

For questions, requests, concerns, complaints, privacy inquiries, or data protection matters, users may contact:

• SmartIV Hauz Ltd — Owner and Operator of Paeflow
• Email: info@smartivhauz.com
• Administrative Contact: admin@smartivhauz.com

Physical business address details may be updated and published on the Platform from time to time.

By accessing, registering for, or using Paeflow, users acknowledge that they have read, understood, and agreed to this Privacy Policy. Users further acknowledge that Paeflow may process information as described in this Policy for purposes including service delivery, security, analytics, compliance, automation, artificial intelligence functionality, and continuous platform improvement.