Privacy Policy (NDPA-Compliant)

Last Updated: Monday, 24th November, 2025

Savvy Bee (“Savvy Bee”, “we”, “our”, “us”) is committed to protecting your privacy and ensuring that your personal data is handled in accordance with the Nigeria Data Protection Act (NDPA) 2023, the NDPR 2019, and other applicable laws.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our website, mobile services, financial tools, and AI-powered features.

By accessing or using our platform, you consent to the practices described in this Privacy Policy.

1. The Data We Collect

A. Information You Provide Directly

Full name
Email address
Phone number
Password or authentication details
Date of Birth (DOB)
Financial goals, budgets, and savings preferences
KYC information (when onboarding begins)
Communication history

Why We Collect Date of Birth (DOB)

We collect your date of birth to:

Verify user eligibility and age requirements
Ensure appropriate access to financial features
Personalize financial insights and recommendations

Your date of birth is used strictly for identification and eligibility purposes and is not shared with third parties except where required to provide core app functionality or comply with legal obligations.

B. Automatically Collected Data

IP address
Device information
Browser type
Usage data and interaction logs
Cookies and tracking data
Location data (where enabled)

C. Financial & Transaction Data (Future App Version)

Spending patterns
Savings behavior
Linked accounts or integrations
Third-party transaction metadata

D. AI & Chat Data (NAHL Chat Feature)

Savvy Bee provides an AI-powered assistant feature (“NAHL Chat”) to help users with financial guidance and receipt analysis.

When you use NAHL Chat, we may collect and transmit the following data to a third-party AI service provider in order to generate responses:

Messages you send to the AI assistant
Images you upload for receipt scanning
Related metadata required to process your request (such as session identifiers)

This data is used only to:

Generate AI responses
Analyze uploaded receipts
Provide financial insights and support features within the app.

We do not use this data for advertising or marketing purposes.

Before any data is sent to our AI service provider, we request your explicit consent within the app. If you do not grant consent, the AI features will remain disabled and no data will be shared with the AI service.

You can:

Withdraw AI consent at any time within the app
Re-enable AI access later if you choose
Use all non-AI features of Savvy Bee without granting AI consent

Our third-party AI service provider processes data in accordance with industry-standard security and privacy practices and provides protections equal to or greater than those described in this policy.

2. How We Use Your Data

Savvy Bee processes your data for the following purposes:

To create and manage your account
To verify age and eligibility requirements
To provide financial advisory tools, dashboards, and AI-powered assistance
To personalize your user experience
To improve product performance
To communicate updates, newsletters, and feature announcements
To conduct analytics and product research
To comply with regulatory requirements
To detect, prevent, and respond to fraud or security incidents

3. Lawful Basis for Processing

We rely on the following legal bases:

Consent — newsletters, waitlist subscription, marketing, and AI feature activation
Contractual necessity — delivering services you sign up for
Legitimate interest — product analytics and fraud monitoring
Legal obligation — KYC, regulatory reporting, financial compliance

4. Cookies & Tracking

Savvy Bee uses cookies and similar technologies to:

Authenticate sessions
Analyze traffic
Improve user experience

You may control cookies through your browser settings.

5. Data Sharing & Third Parties

We may share your data with trusted service providers such as:

Cloud hosting providers
Payment/financial partners
Analytics platforms
Email/CRM tools
AI service providers (for NAHL Chat, where consent is granted)
Compliance partners (DPCO, regulators)

All third parties are bound by NDPA-compliant Data Processing Agreements (DPAs).
We do not sell personal data.

6. Cross-Border Data Transfers

Some service providers (including AI infrastructure providers) may be located outside Nigeria. Where this occurs, we ensure:

Adequacy assessments
Contractual safeguards
Compliance with NDPA Section 41

7. Data Retention

We retain your data only as long as:

Necessary to provide our services
Required by law (financial records, KYC, audits)
Needed to resolve disputes or enforce agreements

AI chat data may be retained only as long as necessary to deliver the requested service or improve system performance, in line with NDPA requirements.

Retention timelines will be outlined in our Data Retention Policy.

8. Your Rights Under NDPA

You have the right to:

Access your personal data
Request correction
Request deletion
Withdraw consent (including AI feature consent)
Object to processing
Request data portability
Submit complaints

To exercise these rights, email:
support@mysavvybee.com

9. Security Measures

Savvy Bee uses administrative, technical, and organizational measures including:

Encryption
Access controls
Secure cloud infrastructure
Monitoring and logging
Regular security reviews

However, no system is 100% secure.

10. Data Breach Management

In the event of a breach:

We will notify you promptly
We will notify the Nigeria Data Protection Commission (NDPC)
We will take immediate corrective actions

11. Children’s Privacy

Savvy Bee does not knowingly collect data from individuals under 18 unless legally authorized.

12. Changes to This Policy

We may update this policy periodically. Changes will be posted with a new effective date.

13. Contact Information

For questions or concerns:
hello@mysavvybee.com

14. Data Protection Officer

Mustapha Rafindadi
Mustapha.rafindadi@byteflow.com.ng
Phone: 09032083063