Privacy Policy
The 36th Solutions Ltd
1. Introduction
The 36th Solutions Ltd ("we", "us", or "our") is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Odogwu mobile application and related services.
2. Information We Collect
We collect the following types of information: • Personal Identification: Full name, phone number, email address, date of birth, and government-issued ID details for KYC verification. • Financial Information: Bank account details, transaction history, wallet balances, and payment information. • Device Information: Device type, operating system, unique device identifiers, and mobile network information. • Usage Data: App usage patterns, features accessed, time spent, and interaction data. • Location Data: General location information to comply with regulatory requirements.
3. How We Use Your Information
We use your information to: • Process transactions and manage your wallet • Verify your identity and comply with KYC/AML regulations • Send transaction notifications and account updates • Provide customer support • Detect and prevent fraud and unauthorized access • Improve our services and develop new features • Comply with legal and regulatory obligations under Nigerian law
4. Information Sharing
We do not sell your personal information. We may share your information with: • Banking and payment partners to process transactions • Identity verification services for KYC compliance • Regulatory authorities as required by Nigerian law (CBN, EFCC, NFIU) • Service providers who assist in operating our platform under strict confidentiality agreements • Law enforcement when required by valid legal process
5. Data Security
We implement industry-standard security measures including encryption in transit and at rest, secure authentication protocols, regular security audits, and access controls. However, no method of transmission over the internet is 100% secure. We encourage you to use strong passwords and keep your account credentials confidential.
6. Data Retention
We retain your personal information for as long as your account is active and as required by Nigerian financial regulations. Transaction records are retained for a minimum of 5 years as required by the Central Bank of Nigeria. You may request deletion of your account, subject to regulatory retention requirements.
7. Your Rights
Under applicable Nigerian data protection laws (NDPR), you have the right to: • Access your personal data • Correct inaccurate data • Request deletion of your data (subject to legal requirements) • Object to certain processing activities • Data portability To exercise these rights, contact us at privacy@odogwu.app
8. Cookies and Tracking
The Odogwu app uses analytics tools to understand usage patterns and improve the service. This data is anonymized and aggregated. We do not use third-party advertising trackers.
9. Children's Privacy
Odogwu is not intended for users under 18 years of age. We do not knowingly collect personal information from minors. If we discover that a minor has provided us with personal information, we will delete it immediately.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes through the App or by email. Your continued use of the App after changes are posted constitutes your acceptance of the updated policy.
11. Contact Us
For privacy-related inquiries or to exercise your data rights, contact: The 36th Solutions Ltd Email: privacy@odogwu.app Address: Lagos, Nigeria Data Protection Officer: dpo@odogwu.app
Last updated: April 2026