Privacy Policy

1. Who We Are

LoadAm is a digital wallet and Virtual Top-Up (VTU) platform operated by JADEMTECH LIMITED, a company duly registered under the laws of the Federal Republic of Nigeria. Our platform allows you to fund a digital wallet and use it to purchase mobile data, airtime, electricity tokens, cable TV subscriptions, and educational PINs.

For the purposes of the Nigeria Data Protection Act 2023 and the Nigeria Data Protection Regulation (NDPR) 2019, JADEMTECH LIMITED is the Data Controller of your personal information collected through the LoadAm platform.

You can contact us about any data privacy matter at: support@loadam.ng

2. Information We Collect

2.1 Information You Provide at Registration

When you create a LoadAm account, we collect:

• Full legal name: used to identify your account and for KYC compliance
• Nigerian mobile phone number: collected at the point of registration
• Email address: verified by a confirmation link before you can access the platform
• Account password: stored as a one-way cryptographic hash; LoadAm cannot read your actual password
• 4-digit transaction PIN: required to authorise every purchase; stored as a bcrypt hash; LoadAm cannot read your actual PIN

2.2 Profile Information (Optional at Tier 1)

After registration, you may optionally complete your profile with:

• State of residence
• Local Government Area (LGA)

These are collected for service personalisation and to support future localised offers. They are not required to use the platform at Tier 1.

2.3 KYC Verification Information (Required for Tier 2)

If you choose to upgrade to Tier 2 for higher transaction limits, we will request your Bank Verification Number (BVN), verified automatically against your bank account and name. Accounts previously verified under our earlier manual process may instead have a National Identification Number (NIN) on file. See Section 8 for how that legacy data is protected and retained.

This information is used solely for identity verification and compliance with Nigerian financial regulations, and will not be shared with third parties except as required by law.

2.4 Payment Information

When you fund your LoadAm wallet, you provide payment details to our licensed payment processor. LoadAm does not store, process, or have access to your card numbers, bank account numbers, or other sensitive payment credentials. All payment data is handled entirely within our payment processor’s secure, regulated infrastructure.

2.5 Service Recipient Information

When you purchase services through LoadAm, you provide:

• Phone numbers: for data and airtime purchases (the number receiving the service)
• Meter numbers and meter type: for electricity token purchases
• Smartcard/IUC numbers: for cable TV subscription purchases
• Exam type and quantity: for educational PIN purchases (WAEC, NECO)

This information is shared with our service providers and partners to fulfil your transaction. We retain it as part of your transaction record.

2.6 Transaction Records

Every transaction on LoadAm generates a permanent record stored securely on our platform. These records include the service type, amount, recipient details, reference number, timestamp, status, and where applicable, the actual deliverable (such as an electricity token or examination PIN). These records are accessible to you through your transaction history at any time.

2.7 Technical and Security Data

When you use LoadAm, limited technical information is automatically generated and retained, such as login timestamps and device type, for the sole purpose of account security and fraud prevention. This information is not used for marketing or profiling.

2.8 KYC and AML Monitoring Data

As part of our Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) obligations, we maintain records of:

• KYC tier status and verification history (submission date, review date, outcome)
• Transaction patterns that may trigger AML review thresholds
• Any account restrictions, suspensions, or flags applied
• Communications with customers about compliance matters

2.9 Support Communications

When you contact LoadAm support by email or WhatsApp, we retain those communications for customer service and dispute resolution purposes.

2.10 What We Do Not Collect

LoadAm does not collect:

• Biometric data of any kind
• Selfies or facial images (not currently used for verification)
• Proof of address documents
• Social media profile information
• Location data beyond your stated state and LGA
• Browsing history outside the LoadAm platform

3. How We Use Your Information

3.1 To Provide and Operate the Platform (Contractual Necessity)

• Creating and managing your LoadAm account
• Processing wallet funding and verifying payments
• Executing VTU and bills payment transactions on your behalf
• Delivering purchased services (data, airtime, electricity tokens, cable TV subscriptions, educational PINs) to specified recipients
• Sending transaction confirmation emails and receipts from noreply@loadam.ng
• Sending password reset and email verification links
• Maintaining your complete transaction history for your records
• Enabling the repeat-transaction and transaction receipt features
• Enforcing KYC tier transaction limits on every purchase

3.2 For Security and Fraud Prevention (Legitimate Interest)

• Detecting unusual transaction patterns that may indicate fraud or account compromise
• Monitoring for AML/CFT red flags as required by Nigerian law
• Protecting your account from unauthorised access
• Identifying and investigating suspected fraudulent accounts or transactions
• Enforcing airtime purchase limits under our anti-airtime-theft policy

3.3 For Regulatory Compliance (Legal Obligation)

• Complying with the Money Laundering (Prevention and Prohibition) Act 2022
• Complying with CBN AML/CFT/CPF Regulations
• Maintaining KYC records as required by applicable regulation
• Filing Suspicious Activity Reports with the NFIU where required
• Responding to lawful requests from regulatory authorities
• Retaining transaction records for the legally required minimum period

3.4 For Service Improvement and Personalisation (Legitimate Interest)

• Understanding which services are most used to improve the platform
• Personalising your dashboard based on your most-used services and providers
• Using your state and LGA to surface relevant local service options

3.5 For Communications (Consent / Legitimate Interest)

• Sending you important service updates and changes to our Terms or Privacy Policy
• Notifying you about the outcome of KYC verification submissions
• Notifying you when a pending transaction has been resolved
• Sending promotional messages about LoadAm services (you may opt out at any time)

4. How We Share Your Information

LoadAm does not sell your personal data to any third party, ever. We share your information only in the following limited circumstances:

4.1 Service Providers (Data Processors)

We work with carefully selected third-party service providers who process data on our behalf solely to operate the LoadAm platform. These providers are bound by appropriate data processing agreements and may not use your data for their own purposes:

• Payment processing: A CBN-licensed payment gateway processes all wallet funding transactions. Your card or bank details never touch LoadAm’s servers.
• VTU and bills aggregation: Licensed Nigerian VTU service providers receive your service recipient details (phone number, meter number, smartcard number, etc.) to fulfil your purchase. They share this with their upstream telecom operators, electricity distribution companies, and cable TV providers as necessary.
• Transactional email delivery: A third-party email delivery service sends all system emails from loadam.ng on our behalf, including verification links, receipts, password resets, and KYC notifications.
• Platform infrastructure: Cloud infrastructure providers host our database, application, and domain. They process data only as required to operate the platform and are contractually prohibited from accessing your data for any other purpose.

4.2 Regulatory and Legal Disclosure

We may disclose your personal information to competent Nigerian authorities where required by law, including:

• The Nigerian Financial Intelligence Unit (NFIU), for mandatory Suspicious Activity Reports
• The Economic and Financial Crimes Commission (EFCC)
• The Central Bank of Nigeria (CBN)
• The Nigeria Data Protection Commission (NDPC)
• Nigerian courts or law enforcement agencies, in response to a valid court order or legal process

Where we are legally permitted to do so, we will notify you before disclosing your information in response to a legal request.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of JADEMTECH LIMITED’s assets, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and of any changes to privacy arrangements that affect you before they take effect.

5. Data Storage and Security

5.1 Where Your Data Is Stored

Your LoadAm account data, transaction records, and KYC information are stored on secure cloud database infrastructure. All storage arrangements meet the requirements of Nigerian data protection law.

5.2 Security Measures

LoadAm applies the following technical and organisational measures to protect your data:

• Encryption in transit: All data between your device and LoadAm is transmitted over HTTPS/TLS
• Data protection: All stored data, including KYC information (NIN/BVN), is protected at the infrastructure level
• Row-level access controls: Database security policies ensure each user can only access their own data; administrative access is restricted to authorised personnel only
• Password security: Passwords are hashed using industry-standard one-way algorithms, so LoadAm cannot read your password
• PIN security: Your 4-digit transaction PIN is stored as a bcrypt hash, so LoadAm cannot read your PIN
• Payment security: Card and bank account details are processed entirely by our regulated payment processor and never stored by LoadAm
• AML monitoring: Automated systems flag unusual transaction patterns for review, protecting both you and the platform from fraud

5.3 Data Breach Response

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach, and will notify you without undue delay, consistent with the Nigeria Data Protection Act 2023.

6. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this policy, subject to the following minimum periods required by law:

• Account registration data: Duration of your active account, plus 5 years after account closure
• Transaction records: Minimum 5 years from the date of each transaction, as required by the Money Laundering (Prevention and Prohibition) Act 2022
• KYC verification records (NIN/BVN and review history): Minimum 5 years from the date of submission, or 5 years after account closure, whichever is later
• AML monitoring records and flagged activity logs: Minimum 5 years
• Support communications: 2 years from the date of the last communication, or longer if relevant to an ongoing dispute or regulatory matter
• Technical/security logs: 90 days

After the applicable retention period, data is securely deleted.

7. Your Rights Under Nigerian Law

Under the Nigeria Data Protection Act 2023 and the NDPR 2019, you have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data LoadAm holds about you
• Right to rectification: Correct inaccurate personal data through your profile settings or by contacting support
• Right to erasure: Request deletion of your personal data, subject to our legal obligations to retain certain records (transaction history and KYC data required by AML/CFT law cannot be deleted before the mandatory retention period)
• Right to restrict processing: Request that we limit how we use your data in certain circumstances
• Right to data portability: Request your personal data in a structured, commonly used, machine-readable format
• Right to object: Object to processing based on legitimate interests, including direct marketing. You can unsubscribe from promotional messages at any time
• Right to withdraw consent: Where processing is based on your consent, withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, contact us at support@loadam.ng. We will respond within 30 days. If you are dissatisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.

8. KYC Data: Special Protections

We treat NIN and BVN information with additional care given their sensitivity:

• BVN data captured through our automated verification is encrypted at the database column level, in addition to standard disk-level encryption at rest; it is only accessible to authorised LoadAm systems for the purpose of identity verification. NIN and BVN data submitted through legacy manual verification is protected by disk-level encryption at rest and access controls, and is only accessible to authorised LoadAm personnel for KYC review
• This data will never be displayed in full to anyone other than authorised reviewers. It will not appear on receipts, transaction histories, or any customer-facing screen
• We will never ask you to share your NIN or BVN through WhatsApp, SMS, phone call, or any channel other than the secure KYC form within the LoadAm platform
• NIN and BVN data is retained for a minimum of 5 years as required by Nigerian AML/CFT regulations, after which it is securely deleted

9. Cookies and Session Data

LoadAm uses essential session tokens and cookies to maintain your login session and deliver the platform’s core functionality. These are strictly necessary for the service to work and do not require your consent.

We do not use advertising cookies, third-party tracking pixels, or behavioural profiling technologies. If this changes in the future, we will update this policy and seek your consent where required under applicable law.

10. Children's Privacy

LoadAm is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If you become aware that a person under 18 has registered for a LoadAm account, please notify us at support@loadam.ng and we will promptly close the account and delete the associated data.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, practices, or applicable law. When we make material changes, we will:

• Update the “Last Updated” date at the top of this document
• Send a notification to your registered email address
• Display a prominent notice on the LoadAm platform

Your continued use of LoadAm after receiving such notification constitutes your acceptance of the updated policy.

12. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or how LoadAm handles your personal data:

• Email: support@loadam.ng
• Website: loadam.ng
• Company: JADEMTECH LIMITED

We aim to respond to all privacy-related enquiries within 5 business days.