1. Introduction
Orjar Technology Ventures ("Orjar", "we", "us", or "our") operates Orjar Finance, a personal finance and budgeting platform for users in Nigeria. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal data when you use our website, mobile web application, and related services (collectively, the "Service").
We process personal data in accordance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR) (as applicable), the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, and other applicable Nigerian laws, including regulations issued by the Central Bank of Nigeria (CBN) where you use Live Mode financial services.
By creating an account or using the Service, you acknowledge that you have read this Privacy Policy. Where required by law, we will obtain your explicit consent before processing sensitive personal data such as identity and financial information.
2. Data Controller and Contact
The data controller for personal data processed through Orjar Finance is Orjar Technology Ventures, Nigeria.
Data Protection Officer / Privacy enquiries: privacy@orjar.app
General support: hello@orjar.app
If you are dissatisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) in accordance with the NDPA.
3. Information We Collect
We collect personal data you provide directly, data generated through your use of the Service, and data received from authorised partners as described below.
- Account data: name, email address, phone number, password (hashed), profile photo (if uploaded), occupation, and authentication logs.
- Planning data: income figures, budget buckets, sub-buckets, expenses, grocery lists, savings jars, investment and T-bill records, credit/debt entries, and other financial planning information you enter in Plan Mode.
- Identity and KYC data (Live Mode): full legal name, date of birth, gender, residential address, Bank Verification Number (BVN), National Identification Number (NIN) where applicable, government-issued ID details and images, proof-of-address documents, and liveness verification results.
- Transaction and wallet data (Live Mode): deposit account details, virtual account numbers, transaction history, transfer references, wallet balances, and reconciliation metadata provided by our banking partner.
- Device and usage data: IP address, browser type, device identifiers, pages viewed, feature usage, crash logs, and performance diagnostics.
- Communications: messages you send to support, feedback, survey responses, and notification preferences.
- Referral and waitlist data: referral codes, invite relationships, and early-access registration details where applicable.
4. Sensitive and Special Categories of Data
Under Nigerian law, certain data we process is classified as sensitive personal data, including biometric data used for liveness checks, government identification numbers (BVN, NIN), and financial account information.
We process sensitive personal data only where necessary to provide Live Mode, comply with CBN Know-Your-Customer (KYC) and Anti-Money Laundering/Counter-Financing of Terrorism (AML/CFT) obligations, prevent fraud, or with your explicit consent.
Raw biometric templates from liveness checks are processed by our verification partner and are not stored by Orjar in unencrypted or reusable form.
5. How We Use Your Information
We use personal data for the following lawful purposes:
- To create and administer your account and authenticate your identity.
- To provide Plan Mode budgeting, expense tracking, savings jars, grocery lists, investments tracking, advisory insights, and related features.
- To activate Live Mode, open and maintain deposit relationships with our banking partner, execute transfers you authorise, and reconcile wallet activity.
- To verify your identity, perform KYC tier upgrades, and comply with regulatory reporting obligations.
- To send service notifications, security alerts, transaction confirmations, and marketing communications where you have opted in.
- To detect, investigate, and prevent fraud, abuse, money laundering, and other unlawful activity.
- To improve the Service, conduct analytics, and develop new features.
- To enforce our Terms of Service, resolve disputes, and protect our legal rights.
6. Legal Bases for Processing
Depending on the processing activity, we rely on one or more of the following legal bases under the NDPA and NDPR:
- Performance of a contract — to provide the Service you signed up for.
- Legal obligation — to comply with CBN, NDPC, tax, AML/CFT, and court orders.
- Legitimate interests — to secure the platform, prevent fraud, and improve user experience, balanced against your rights.
- Consent — for optional marketing, certain analytics, and processing where consent is specifically required.
7. BVN, NIN, and Identity Verification
When you activate Live Mode or upgrade your account tier, we collect identity information required under CBN tiered KYC rules.
BVN and NIN are verified through licensed identity verification providers and transmitted to Anchor Microfinance Bank (our banking partner) for account opening and ongoing compliance.
Where stored by Orjar, BVN and NIN are encrypted at rest using industry-standard encryption. We do not display full BVN or NIN in the app interface after submission.
You may withdraw consent for non-mandatory processing by contacting privacy@orjar.app; however, withdrawal may limit or terminate your ability to use Live Mode where identity data is legally required.
9. International Data Transfers
Some of our service providers may process data outside Nigeria. Where personal data is transferred internationally, we implement appropriate safeguards under the NDPA, including contractual clauses, adequacy assessments, and security controls, to ensure your data receives a level of protection comparable to Nigerian law.
10. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this policy, unless a longer retention period is required by law.
Account and planning data is retained while your account is active and for a reasonable period after closure to resolve disputes and comply with legal obligations.
KYC, transaction, and AML records may be retained for periods prescribed by CBN and AML regulations (typically five to ten years or longer where litigation or investigation requires).
When data is no longer required, we securely delete or anonymise it in accordance with our retention schedule.
11. Data Security
We implement technical and organisational measures designed to protect personal data, including encryption in transit (TLS), encryption at rest for sensitive fields, access controls, audit logging, and secure development practices.
Authentication may include email verification, multi-factor authentication (MFA), and transaction PINs for sensitive wallet actions.
No method of transmission or storage is completely secure. You are responsible for safeguarding your login credentials and promptly notifying us of suspected unauthorised access.
12. Your Rights Under Nigerian Law
Subject to applicable exceptions, you have the following rights regarding your personal data:
To exercise these rights, email privacy@orjar.app with sufficient information to verify your identity. We will respond within the timeframe required by the NDPA (typically within one month, extendable where permitted).
- Right of access — request a copy of personal data we hold about you.
- Right to rectification — correct inaccurate or incomplete data.
- Right to erasure — request deletion where processing is no longer lawful or necessary.
- Right to restrict processing — in certain circumstances, limit how we use your data.
- Right to data portability — receive your data in a structured, machine-readable format where applicable.
- Right to object — object to processing based on legitimate interests or direct marketing.
- Right to withdraw consent — where processing is consent-based, without affecting prior lawful processing.
14. Children and Minors
The Service is not directed at persons under eighteen (18) years of age. We do not knowingly collect personal data from minors.
If you believe a minor has provided personal data to us, contact privacy@orjar.app and we will take steps to delete such data.
15. Automated Decision-Making
We use automated systems for fraud detection, transaction classification, budget insights, and advisory recommendations. These systems do not produce legal or similarly significant effects without human review where required by law.
You may request information about significant automated decisions affecting you and, where applicable, human intervention.
16. Data Breach Notification
In the event of a personal data breach likely to result in risk to your rights and freedoms, we will notify the Nigeria Data Protection Commission and affected users within the timeframes required by the NDPA, and describe the nature of the breach and remedial steps taken.
17. Changes to This Policy
We may update this Privacy Policy from time to time to reflect legal, regulatory, or operational changes. The "Last updated" date at the top indicates the latest revision.
Material changes will be communicated through the app, by email, or by prominent notice on our website. Continued use after the effective date constitutes acceptance of the updated policy.
18. Contact Us
Privacy and data protection enquiries: privacy@orjar.app
Legal enquiries: legal@orjar.app
Orjar Technology Ventures — Orjar Finance