1. Scope and controller
This Notice applies to Escrow Village websites, apps, user accounts, wallets, escrow transactions, Market activity, Villages, chats, support, advertising and related security operations. EscrowVillage Limited is responsible for personal-data processing carried out for the platform, subject to the role of any independent third party that processes data for its own purposes.
Privacy questions or requests may be submitted through the official Escrow Village Support route. We may ask for enough information to verify that a person making a request is the relevant data subject or is authorised to act for them.
2. Information we collect
3. Where information comes from
We receive information directly from you, from other users involved in a transaction or complaint, from your device and browser when you use the service, from platform logs and derived risk analysis, and from service providers or authorities where permitted by law. A buyer or seller may provide information about the other party as part of an escrow, dispute or support case.
4. Why we use information
- Create, authenticate, secure and recover accounts.
- Verify identity, age, business authority or eligibility for controlled features.
- Operate wallets, deposits, withdrawals, conversions and escrow transactions.
- Deliver messages, media, read receipts, notifications and support.
- Publish and moderate Marketplace listings, Villages, reviews and ads.
- Prevent scams, fraud, referral abuse, account compromise, suspicious-fund movement and other misuse.
- Investigate disputes, make settlement decisions and maintain evidence and audit trails.
- Measure service performance, fix defects, improve usability and maintain availability.
- Comply with legal obligations, lawful requests, court processes and regulatory requirements.
5. Lawful bases
Depending on the processing activity and applicable law, we may rely on one or more lawful bases:
- Contract or steps requested before a contract: for account services, transactions, escrow instructions, support and requested platform features.
- Legal obligation: where processing is required by applicable law or lawful authority.
- Legitimate interests: for platform security, fraud prevention, service integrity, abuse prevention, dispute administration and improvement, where those interests are not overridden by your rights and freedoms.
- Consent: where consent is appropriate or legally required, including certain optional communications or processing. Consent may be withdrawn where the law permits.
- Other lawful grounds: where processing is necessary to protect vital interests, perform a public-interest task, establish or defend legal claims, or process sensitive personal data under an applicable legal condition.
6. Escrow, wallet and transaction data
We keep transaction records to operate balances, identify funding sources, process releases or returns, investigate failed or returned transfers, trace suspicious exposure, support audits, resolve disputes and correct ledger errors. Transaction records can remain relevant after an escrow is completed because chargebacks, legal claims, fraud reviews, accounting or security investigations may arise later.
Counterparties may see information reasonably necessary for a deal, such as username, role, agreed terms, transaction status and relevant chat content. They do not automatically receive your full KYC file.
7. Fraud prevention, profiling and significant decisions
Escrow Village may use automated or semi-automated signals to identify unusual or connected activity. Signals may include device fingerprints, browser characteristics, IP relationships, referral relationships, login history, transaction patterns, suspicious-fund tracing, Scam Alerts and other risk indicators.
A signal can lead to additional verification, withdrawal review, account restriction, transaction hold, referral reversal or staff investigation. Risk signals are not necessarily proof of wrongdoing. Where a decision is based solely on automated processing and produces a legal or similarly significant effect, you may have rights under applicable law to request human intervention, express your view and contest the decision.
9. International transfers
Some technology or service providers may process information outside Nigeria. Where personal data is transferred internationally, we will use a transfer mechanism or safeguard required by applicable data-protection law, taking account of the destination, recipient and nature of the processing.
10. How long we keep information
We keep personal data only for as long as necessary for the relevant purpose or another lawful basis. Retention is determined by criteria including the type of record, transaction lifecycle, dispute or chargeback risk, security needs, legal limitation periods, accounting requirements, regulatory obligations and whether an investigation or claim is open.
- Temporary session and cache data may be kept for a short technical period.
- Account and profile data may be kept while an account is active and for a reasonable period afterward where necessary for security, claims or law.
- Transaction, wallet, escrow, dispute and fraud records may be kept longer because they support audit trails, investigations, legal claims and financial integrity.
- Content may be removed from the visible product while a limited copy remains where necessary for dispute evidence, security, backup integrity or legal compliance.
When data is no longer necessary and no lawful basis requires retention, it should be deleted, anonymised or otherwise handled in accordance with applicable law and operational safeguards.
11. Security
We use technical and organisational measures designed to protect personal data, including role-based access, authentication controls, audit trails, monitoring, transaction controls and security review. No internet service can promise absolute security. You should protect passwords and OTPs, keep devices secure and report suspected compromise promptly.
12. Cookies, local storage and device identifiers
The platform may use cookies, local storage, session storage, service-worker or PWA storage, route-warming caches and device identifiers to maintain sessions, remember theme or interface choices, improve speed, deliver notifications, prevent abuse and secure accounts. Some identifiers are designed to help recognise repeated or connected device activity for fraud prevention.
Blocking essential browser storage may prevent login, security or app features from working correctly. Optional technologies should be handled according to applicable consent requirements and available settings.
13. Messages and notifications
We may send service communications about verification, deposits, withdrawals, conversions, escrow activity, disputes, security, support, account restrictions and other requested features. Promotional communications, where used, are handled according to applicable law and available preferences.
Chat and media content may be processed to deliver the conversation, show read status, prevent abuse, support users and resolve disputes. Do not send unnecessary sensitive information in a public or inappropriate channel.
14. Children and age controls
Escrow Village is not intended to enable a person who lacks legal capacity or fails the platform's minimum age requirements to complete controlled financial or verification features. We may use date-of-birth or identity checks to enforce age restrictions and may refuse verification or restrict an account that does not qualify.
If you believe a child has provided personal data contrary to applicable rules, contact Support so the matter can be reviewed.
15. Your rights
Subject to the Nigeria Data Protection Act 2023 and any applicable limitations, you may have rights to:
- be informed about processing and obtain access to your personal data;
- request correction of inaccurate, incomplete, outdated or misleading data;
- request erasure where data is no longer necessary and no other lawful basis requires retention;
- request restriction of processing in applicable circumstances;
- withdraw consent where processing relies on consent;
- object to certain processing, including direct marketing;
- receive data in a commonly used electronic format or exercise portability rights where applicable;
- not be subject to certain solely automated significant decisions and to seek human intervention where the law provides;
- lodge a complaint with the Nigeria Data Protection Commission.
Rights are not absolute. For example, we may need to retain transaction or fraud records to comply with law, protect users, resolve claims or maintain platform integrity. We will explain an applicable limitation where required.
16. Complaints to the NDPC
You may first contact Escrow Village through the official Support route so we can investigate a privacy concern. You also have the right, where applicable, to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or pursue another remedy available under law.
17. Security incidents and personal-data breaches
We investigate suspected personal-data breaches and maintain incident records as required. Where a breach creates the level of risk requiring notification under applicable law, we will notify the NDPC and affected data subjects within the legally required framework and provide available information in clear language.
18. Changes and contact
We may update this Notice when products, data practices, suppliers or laws change. The effective date above identifies this version. Material changes may be communicated through the platform or another appropriate channel.
For privacy questions, data-rights requests or concerns about automated fraud decisions, use the official Escrow Village Support route and clearly state that the request concerns privacy or personal data.