How we look after your data

Who we are

The programme is run by MyPayble Technologies Limited (“Payble”, “we”), Plot 654 Sani Abacha Way, by FCDA/NTA HQRS, Area 11, Garki, Abuja. We decide why and how the personal data in this notice is used, which makes us the “data controller”. You can reach our data protection team at privacy@mypayble.com.

This notice covers: people who apply to be agents; applicants and agents who sign in to the agent portal; people that an applicant names (a next of kin or a guarantor); and merchants and members of the public who use the agent verification page. It does not cover the Payble app or Payble's merchants: those have their own privacy policy.

What we collect, and why

We ask for things step by step, only when that step needs them. Nothing here is collected from a source other than you, our own team's notes, and (for next of kin and guarantors) the applicant who named them.

When	What	Why, and our basis under the law
You apply	Your name, email, phone, state, and optionally your local government area and town; your CV (a PDF).	To decide whether to take your application forward, which is a step you ask us to take before entering an agreement. We also record which version of this notice you saw.
Interviews	The time you book, and notes our team writes about you.	To run the interview and assess you fairly (our legitimate interest in recruiting well).
Other roles at Payble	If you tell us you would be open to other work at Payble (for example customer support) and agree to be kept in mind: your name, contact details and CV are copied to our hiring team's talent pool, with the kinds of work you could suit, a short note from our team on why, and a record of who noted your agreement, how, and when.	Your agreement (consent). We email you to say what was kept. You can change your mind at any time by replying to that email or writing to us, and we will remove you from the talent pool. It does not affect your agent application.
Reading your CV	When someone on our team presses a button, an automated tool reads one CV and suggests kinds of work it points to. Before it does, your email, phone numbers, web links and your name are removed from the text.	Our legitimate interest in finding the right role for people. It runs on our hosting provider's own AI service (Cloudflare), not on a third party's. It only suggests: it does not score or rank anyone, and a person on our team always makes every decision about you.
Your portal login	Your email and a password (stored only as a one-way scramble, never readable), and when you sign in.	To let you into your own portal and keep it secure.
Trying to sign in	Each time someone tries to sign in, asks for a password link, opens one, or we email you a sign-in link: the email address typed (never the password), whether it worked and, if not, why (for example “no password chosen yet”), the time, your network address and device type. The same for our own team’s sign-ins.	So that if you cannot get in, our team can see what went wrong and fix it, instead of guessing. It is also how we spot someone trying to break in (our legitimate interest in running a secure service). It is read by the coaches who help applicants and, for our own team’s sign-ins, by administrators only.
Training and the test	Which modules you opened and finished and when; your test answers and score; how long the test took; the network address and device type it was taken from.	To train and certify you. The network address, timing and similarity checks help keep the test honest (our legitimate interest in a fair certification). A coach reviews your result and makes the decision. The multiple-choice part is marked automatically, but no decision about you is made by a computer alone.
Agreements	The name you typed, your drawn signature, the time, your network address and device, and a fingerprint of the exact text you agreed to. For the agent agreement, also the home address and National Identification Number (NIN) you type into it (the agreement names you by them), the date it was signed, and a copy of Payble’s own signature as it was when you signed, which the system applies automatically. Your NIN is kept only inside your signed agreement: it is not shown in any list. If you signed an earlier version we ask you to sign the updated one, and keep both.	To have a reliable record of what you agreed to, and to be able to prove it if there is ever a dispute.
Your details and documents	Your full name, phone numbers, home address, where you will work, a passport photograph, the type of ID you hold and a copy of it; your next of kin (name, relationship, phone, address); your guarantor (the same, plus occupation) and a copy of their ID; your shirt size.	To verify who you are before we issue an Agent ID, to protect merchants and Payble from fraud, and to meet legal obligations that apply to businesses in financial services. We ask for your consent to the parts that need it, and you can withdraw it (see your rights).
Your Agent ID	Your Agent ID, and a secret code in the QR code on your badge.	So a merchant can check you are genuine. Anyone who types your Agent ID sees only your first name and last initial, your state, and whether you are active. Only someone who scans your badge's QR code also sees your photo.
Working as an agent	Training you complete, your status, whether swag was sent, and messages we send you.	To run the agent relationship and keep you informed.
When you use the site	A sign-in cookie; your network address, held for a couple of days to stop abuse.	To keep you signed in and to protect the system. These are strictly necessary, so we do not ask you to accept them.

Your next of kin and guarantor. If you name someone, we hold the details you give us about them, and their ID copy if you upload it. You confirm on the form that they know and agree. They have the same rights described below and can contact us.

Cookies. We use only the cookie that keeps you signed in. We do not use advertising or tracking cookies, and we load nothing from third-party trackers, fonts or image services: every font, picture and video comes from our own site. Our hosting provider (see below) may measure basic, anonymous site performance and detect bots.

Age. The programme is for people aged 18 or over. If you think a child has applied, tell us and we will remove it.

Who sees it

• Our team. Recruiters, coaches and administrators who need it to do their job. Every time someone opens a CV, a signed agreement, an identity document or a full record, it is written down. Only a small number of administrators can export or delete data.
• Companies that help us run the system (“processors”). Cloudflare (hosting, our database, private file storage and security) and Google (our work email, calendar and training-video storage). They may only use your data to provide those services to us.
• Merchants and the public see only what the verification page shows, as described in the table above.
• Authorities when the law requires it, and professional advisers under a duty of confidence.
• We do not sell your data or use it for advertising.

Outside Nigeria. Cloudflare and Google run global services, so your data may be processed in other countries. Where the law requires safeguards for that, we rely on the contracts and mechanisms those providers offer and the ones the law recognises.

How long we keep it

We keep personal data only as long as there is a reason to, and then delete it. These are our limits:

Data	How long
Applications that end without you becoming an agent (rejected or withdrawn)	12 months after the decision, then your CV, details, test answers and notes are deleted.
Applications that go quiet before interview or training	18 months without movement, then deleted.
The talent pool (other roles at Payble)	Up to 12 months after the last activity on your entry, unless you are hired or in the middle of a process, or you ask us to remove it sooner.
If you become an agent	For as long as you are an agent, and afterwards for as long as the law, or our need to deal with a legal claim, requires. We will tell you the period once it is fixed.
The signed agent agreement record	Kept as evidence of the agreement, even if other data is deleted at your request.
Notifications, sign-in records and site security records	Notifications 90 days; the record of sign-in attempts and sign-in emails 90 days; network-address abuse counters about 2 days.
Our internal audit trail (who did what)	24 months.
Records of privacy requests	36 months after we answer.

Deleted means deleted from our live system and private storage. Copies in our cloud provider's short-term backups disappear as those backups expire.

Your rights

You can ask us to:

• Show you the personal data we hold about you, and give you a copy.
• Correct anything that is wrong or incomplete. (You can also fix your contact details yourself in your portal.)
• Delete your data. We will, unless the law lets or requires us to keep something, in which case we tell you what and why.
• Stop or limit how we use it, or object to a use that relies on our legitimate interest.
• Give you your data in a portable format (a JSON file).
• Withdraw your consent at any time, where we rely on it. This does not affect what we did before.

How. If you have a portal account, use “Your data” on your Profile page. Otherwise email privacy@mypayble.com. We may need to check it is really you before we act. We aim to reply within 30 days. There is no charge unless a request is clearly unreasonable or repeated.

If you are not happy. Please tell us first so we can put it right. You may also complain to the Nigeria Data Protection Commission (ndpc.gov.ng), or the data protection authority where you live.

How we protect it

Everything travels over encrypted connections. Your CV and identity documents sit in private storage that is not reachable from the internet and are only shown to authorised staff, with every view logged. Passwords are stored only as one-way scrambles, and staff accounts are locked to named people. We test these protections regularly. If a breach ever puts your rights at risk, we will tell you and the regulator within the time the law sets.

Other countries

When the programme opens in another country, a section for that country will be added here, naming its law, its regulator and any extra rights you have there.

We update this notice when what we do changes, and change the version and date at the top. Each applicant's record shows which version they saw when they applied.