Privacy Policy

Effective Date: 8th August 2025

Last Updated: 8th August 2025

This Privacy Policy describes how [Your Company Legal Name] ("we", "us", "our") collects, uses, stores, shares, and protects your personal information when you use Dumebi, our personal finance artificial intelligence (AI) chatbot accessible via WhatsApp and other platforms (the "Service").

By accessing or using Dumebi, you consent to the practices described in this Privacy Policy. If you do not agree, you must not use the Service.

1. SCOPE OF THIS POLICY

This Privacy Policy applies to all users of Dumebi in Nigeria and elsewhere. It covers information collected via WhatsApp, our website, and any other platform where Dumebi operates.

2. INFORMATION WE COLLECT

We collect the following categories of information:

2.1 Personal Identification Information

  • Full name
  • Phone number
  • Email address
  • Date of birth
  • Bank Verification Number (BVN)
  • Government-issued identification (e.g., National ID, International Passport, Driver's License)
  • Proof of address

2.2 Financial Information

  • Linked bank account details (account number, bank name)
  • Transaction history and records
  • Wallet balance and usage history

2.3 Device & Technical Information

  • Device type and model
  • IP address
  • Operating system and browser type
  • WhatsApp account metadata

2.4 Usage & Interaction Data

  • Chat messages exchanged with Dumebi
  • Service preferences and settings
  • Feedback, survey responses, and complaint submissions

2.5 Third-party Data

We may receive information from banks, payment processors, or other partners to facilitate transactions or verify your identity.

3. HOW WE COLLECT INFORMATION

We collect data:

  • Directly from you when you register, initiate transactions, or interact with Dumebi.
  • Automatically via your device when using the Service.
  • From third parties such as banks, payment providers, and verification services.

4. HOW WE USE YOUR INFORMATION

We process your information to:

  1. Provide and maintain the Service.
  2. Process transactions, bill payments, and money transfers.
  3. Personalize your financial tips and recommendations.
  4. Conduct identity verification (KYC) in compliance with CBN guidelines.
  5. Detect and prevent fraud, money laundering, and unauthorized transactions.
  6. Comply with legal and regulatory obligations.
  7. Communicate with you about updates, transactions, and support.

5. AI DATA PROCESSING

5.1 Dumebi uses AI to process your chat messages and provide responses.
5.2 While AI processing enables personalization, we do not sell or rent chat transcripts to third parties.
5.3 Data from AI interactions may be anonymized and aggregated for service improvement.

6. SHARING OF INFORMATION

We may share your information:

  • With financial institutions (banks, payment processors) to complete transactions.
  • With regulators such as the Central Bank of Nigeria (CBN) and the Nigeria Deposit Insurance Corporation (NDIC) for compliance.
  • With service providers for hosting, fraud detection, and identity verification.
  • When required by law or to protect our legal rights.
  • In a business transfer, such as a merger or acquisition.

We do not sell your personal information to marketers.

7. COOKIES & TRACKING

7.1 If you access Dumebi via our website or web dashboard, we may use cookies and similar technologies to enhance your user experience.
7.2 You may disable cookies via your browser settings, but some features may not function correctly.

8. DATA STORAGE & SECURITY

8.1 We store your data on secure servers with encryption in transit and at rest.
8.2 Access to personal data is restricted to authorized staff and service providers bound by confidentiality agreements.
8.3 Despite our measures, no security system is infallible, and we cannot guarantee absolute protection.

9. DATA RETENTION

We retain personal data only as long as necessary to:

  • Fulfil the purposes outlined in this Policy.
  • Comply with regulatory requirements (e.g., CBN's record-keeping obligations).
  • Resolve disputes and enforce agreements.

After retention periods expire, data will be securely deleted or anonymized.

10. YOUR RIGHTS UNDER NDPR

You have the right to:

  • Access your personal data.
  • Request correction of inaccurate data.
  • Request deletion of your data (subject to regulatory requirements).
  • Object to certain processing activities.
  • Withdraw consent where processing is based on consent.
  • Request data portability to another service provider.

Requests may be made via the contact information in Section 15.

11. CHILDREN'S PRIVACY

Dumebi does not knowingly collect data from individuals under 16 without parental or guardian consent. If we discover such data has been collected without consent, it will be deleted promptly.

12. INTERNATIONAL DATA TRANSFERS

Where your data is transferred outside Nigeria, we will ensure that adequate protection measures are in place, consistent with NDPR requirements.

13. DATA BREACH NOTIFICATION

In the event of a data breach likely to result in significant harm, we will notify affected users and relevant authorities in accordance with NDPR timelines.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. Updated versions will be posted with a revised "Last Updated" date. Continued use of the Service after changes take effect constitutes acceptance.

15. CONTACT INFORMATION

For questions, complaints, or requests related to your personal data, contact:

Dumbledore Solutions LTD
Email: hello@dumbledoretech.com
Phone: +23470 66475316
Address: GOSHEN ESTATE, DOGONGAD, LOKOGOMA, ABUJA., LOKOGOMA, ABUJA