BettaLyfe
Privacy Policy
Nigeria Data Protection Act 2023 Compliant
Last Updated: 1st June 2026 | Version 2.0
4c Idowu Martins Street, Victoria Island, Lagos, Nigeria
1. Introduction
BettaLyfe Digital Services Limited (BettaLyfe, we, us, or our), incorporated in Nigeria under CAMA 2020, is committed to protecting the privacy and personal data of all users of the BettaLyfe platform, mobile application, and website (the Platform).
This Privacy Policy explains how we collect, use, store, share, and protect your personal data under the Nigeria Data Protection Act 2023 (NDPA) and all applicable Nigerian laws. BettaLyfe is registered with the NDPC as a Data Controller of Major Importance (DCPMI). By using the Platform you confirm that you have read and accepted this Policy.
2. Data Controller Details
| Field | Details |
|---|---|
| Company Name | BettaLyfe Digital Services Limited |
| Address | 4c Idowu Martins Street, Victoria Island, Lagos, Nigeria |
| Privacy Email | privacy@bettalyfe.com |
| Data Protection Officer | dpo@bettalyfe.com |
| Customer Support | support@bettalyfe.com | +234-916-000-8850 |
3. Personal Data We Collect
3.1 Identity and Verification Data
- Full legal name, date of birth, gender, and nationality
- Bank Verification Number (BVN) — mandatory per CBN regulations
- National Identification Number (NIN) — mandatory per CBN 2024 circular
- Government-issued photo ID (National ID Card, Voter's Card, Driver's Licence, or International Passport)
- Passport photograph and liveness/selfie biometric image (Tier 3 KYC)
3.2 Contact Data
- Phone number (primary and alternate), email address
- Residential and business address
- Next of kin name and contact details
3.3 Financial and Wallet Data
- Virtual bank account number (issued via Providus Bank)
- Wallet balance and full transaction history
- BettaCredit balance and service redemption records
- Gift card purchase and usage records
- Bill payment history (airtime, data, electricity, cable TV)
- Loan application, disbursement, and repayment data (processed via Unicorn MFB)
- Payment card details (tokenised only — full card numbers are never stored by BettaLyfe)
3.4 Health Data — Sensitive Personal Data
Health data is a special category of sensitive personal data under Section 30 of the NDPA 2023. We collect and process health data ONLY with your explicit, freely-given consent.
- MyBettaCare health plan type and subscription details
- Claims history (processed via AXA Mansard Insurance and NEM Health)
- Pre-existing condition disclosures made during plan enrolment
- Dependant/family member data provided for health coverage
3.5 Pension and Savings Data
- Personal Pension Plan (PPP) contributions and balance (managed via Pension Managers)
- Partial withdrawal history and retirement fund activity
3.6 Device and Technical Data
- Device type, operating system, and unique device identifier
- IP address and approximate location (city/state level only — no GPS tracking)
- App usage patterns, session duration, and crash/error logs
4. How We Collect Your Data
| Source | Purpose |
|---|---|
| Direct provision | When you register, complete KYC, apply for a product, or contact support |
| Providus Bank | In connection with your virtual wallet account operation and fund holding |
| NIBSS | Automated real-time BVN verification at onboarding |
| NIMC | Automated real-time NIN verification at onboarding |
| AXA Mansard / NEM Health | When you enrol in or use a MyBettaCare health plan |
| Unicorn MFB | When you apply for or repay a loan product |
| Pension Managers | In connection with your Personal Pension Plan (PPP) account |
| Paystack | Payment processing data for wallet funding |
| Licensed credit bureaus | Credit data for loan eligibility assessment |
5. Legal Basis for Processing
| Processing Activity | Legal Basis |
|---|---|
| Account registration and KYC | Contract performance; Legal obligation (CBN KYC) |
| BVN and NIN verification via NIBSS/NIMC | Legal obligation (CBN 2024 KYC circular) |
| Virtual wallet (Providus Bank) | Contract performance |
| Health insurance — AXA Mansard / NEM Health | Explicit consent; Contract performance |
| Health data processing | Explicit consent (required separately at enrolment) |
| Personal Pension Plan (PPP) | Contract performance; Legal obligation (PenCom) |
| Loan processing (Unicorn MFB) | Contract performance; Legitimate interests |
| AML/fraud monitoring and NFIU reporting | Legal obligation (MLPPA 2022) |
| BettaCredit and gift card management | Contract performance |
| Marketing communications | Consent (withdrawable at any time) |
| Regulatory reporting (CBN, NFIU, NAICOM, NDPC) | Legal obligation |
6. Data Sharing and Disclosure
We do not sell your personal data under any circumstances.
6.1 Licensed Service Partners
| Partner | Role |
|---|---|
| Providus Bank | Virtual wallet operation; holding all user funds in trust |
| Paystack | Payment processing for wallet funding |
| AXA Mansard Insurance Plc | Underwriting and administering MyBettaCare plans |
| NEM Insurance Plc (NEM Health) | Underwriting and administering MyBettaCare plans |
| Unicorn Microfinance Bank | Loan origination, disbursement, and repayment |
| Pension Managers | Personal Pension Plan (PPP) contribution management |
| NIBSS | Real-time BVN verification |
| NIMC | Real-time NIN verification |
| Licensed credit bureaus | Loan eligibility assessment |
| Bill payment aggregators | Airtime, data, electricity, and cable TV payments |
All partners are bound by Data Processing Agreements (DPAs).
6.2 Regulatory Disclosure (required by Nigerian law)
- Central Bank of Nigeria (CBN)
- Nigerian Financial Intelligence Unit (NFIU)
- Economic and Financial Crimes Commission (EFCC)
- National Insurance Commission (NAICOM)
- National Pension Commission (PenCom)
- Nigeria Data Protection Commission (NDPC)
7. Data Retention
| Data Category | Retention Period |
|---|---|
| Account and identity data | 5 years after account closure (MLPPA 2022 minimum) |
| Transaction records (wallet, loans, payments) | 5 years from transaction date |
| Health insurance records (AXA Mansard / NEM Health) | 5 years after policy expiry |
| Loan records (Unicorn MFB) | 5 years from loan closure |
| Pension records | Duration of plan + 5 years |
| Customer support and communications | 2 years |
| AML/KYC audit logs | 5 years |
8. Your Rights Under the NDPA 2023
| Right | What It Means |
|---|---|
| Right of Access | Request a copy of all personal data we hold about you |
| Right to Rectification | Request correction of inaccurate or incomplete data |
| Right to Erasure | Request deletion (subject to legal retention obligations) |
| Right to Data Portability | Receive your data in a structured, machine-readable format |
| Right to Object | Object to processing based on legitimate interests or direct marketing |
| Right to Withdraw Consent | Withdraw consent for consent-based processing at any time |
| Right to Complain | Lodge a complaint with the NDPC |
To exercise any right, email privacy@bettalyfe.com. We will respond within 30 days.
9. Data Security
- All sensitive data encrypted at rest (AES-256) and in transit (TLS 1.3)
- BVN and NIN stored only as tokenised references — raw digits are not retained after verification
- Role-based access controls limit data access to authorised personnel only
- Annual penetration testing by an independent security firm
- In the event of a data breach, the NDPC and affected users will be notified within 72 hours (Cybercrimes Act 2024)
10. Children and Minors
The Platform is for users aged 18 and above. We do not knowingly collect personal data from anyone under 18. Dependant family members (including minors) may be added to MyBettaCare plans by an eligible adult — their health data is processed solely for coverage purposes.
11. Contact Us
| Contact Type | Details |
|---|---|
| Privacy requests and complaints | privacy@bettalyfe.com |
| Data Protection Officer | dpo@bettalyfe.com |
| General support | support@bettalyfe.com | +234-916-000-8850 |
| Postal address | 4c Idowu Martins Street, Victoria Island, Lagos, Nigeria |
| Escalate complaint to regulator | Nigeria Data Protection Commission |
