Privacy Policy

1. Introduction

Nubisoft Limited respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how Nubisoft Limited collects, receives, uses, stores, shares, protects and otherwise processes personal data in connection with NubiBooks.

NubiBooks is a business management, bookkeeping, invoicing, payment and related technology platform owned and operated by Nubisoft Limited.

In this Privacy Policy, references to "Nubisoft", "NubiBooks", "we", "us" or "our" mean Nubisoft Limited, as applicable. References to "you" or "your" mean a person who accesses or uses NubiBooks, including a business owner, merchant, staff user or other authorised user.

Our principal place of business for the purposes of this Privacy Policy is Magodo Phase 2, Lagos, Nigeria.

This Privacy Policy should be read carefully because it explains what information we collect, why we collect it, how it may be used, the circumstances in which it may be disclosed and the rights available to you.

Where the law requires us to obtain your specific consent before carrying out a particular type of processing, we will request that consent separately.

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data processed through or in connection with NubiBooks, including our website, web application, mobile applications, payment and invoice pages, customer payment interactions, artificial intelligence and voice features, customer support channels, emails, SMS, WhatsApp messages, push notifications and other services made available by Nubisoft in connection with NubiBooks.

This Privacy Policy does not govern an independent website, application or service operated by another organisation merely because NubiBooks contains a link to that service.

Where you leave NubiBooks and use a service operated independently by another organisation, the privacy policy and terms of that organisation may apply.

3. Applicable data protection framework

Nubisoft processes personal data in accordance with applicable Nigerian law, including the Nigeria Data Protection Act 2023 and applicable regulations, directives, guidelines and lawful requirements of the Nigeria Data Protection Commission.

Depending on the particular activity involved, other Nigerian laws and regulatory requirements relating to consumer protection, financial transactions, taxation, company administration, anti-money laundering, cybersecurity, electronic communications and lawful regulatory reporting may also apply.

Our banking, payment and verification partners may be subject to additional regulatory obligations imposed by their respective regulators.

Where a person accesses NubiBooks from another jurisdiction, applicable data protection requirements in that jurisdiction may also apply to our processing where the law requires.

4. Our role in relation to personal data

For personal data that Nubisoft collects directly in order to operate NubiBooks, manage your account, verify you, communicate with you, provide payment services or otherwise operate the platform, Nubisoft generally determines the purpose and manner of processing and acts as a data controller.

NubiBooks also enables merchants to record information relating to their own customers, suppliers, employees, staff users and business transactions.

Where a merchant independently determines why it collects and records personal data about its customers or other persons and uses NubiBooks to manage that information, the merchant is responsible for its use of that information and Nubisoft may process such information on behalf of the merchant in providing NubiBooks.

Nothing in this Privacy Policy removes a merchant's responsibility to handle the personal information of its own customers lawfully.

5. Information we may collect

The information we process depends on the NubiBooks services you use.

We may collect or process the following categories of information:

• Account information, including your name, email address, telephone number, country, login information and other information required to create and maintain your account.
• Business information, including business name, business type, business address, contact information, registration details, tax information, VAT information, logo, business category, branch information and other information supplied when setting up or managing a business.
• Identity and verification information, including information required to confirm your identity, business registration, directorship, ownership or bank account. Depending on the verification being performed, this may include BVN, NIN, CAC information and information returned by authorised identity or business verification providers.
• Banking and payment information, including bank name, account number, account name, virtual account information, transaction references, payment amounts, settlement information, payout details and related transaction information.
• Business records, including invoices, receipts, sales, expenses, products, stock information, customers, suppliers, orders, payments, payouts, wallet activity and accounting records created or maintained through NubiBooks.
• Information about your customers, including names, telephone numbers, email addresses, addresses, invoice information, transaction amounts and other information that you choose to record about customers while using NubiBooks.
• Staff information, including the names, contact details, roles and permissions of persons invited or added to a business account.
• Files and documents, including business logos, product photographs, receipts, expense attachments, business registration documents, verification documents, spreadsheets and other files uploaded to NubiBooks.
• AI and voice information, including text that you type into NubiBooks AI features, voice input that you intentionally provide, transcripts generated from voice input, prompts, instructions and information required to carry out the action you request.
• Device and technical information, including device type, operating system, browser, application version, IP address, access times, technical logs, error information and information reasonably required to secure and operate the Service.
• Notification information, including device or notification tokens used to deliver push notifications.
• Communications, including messages, complaints, support requests, feedback and other communications sent to Nubisoft.
• Information received from third parties, including payment notifications, transaction references, verification results, bank account information, delivery information and other information supplied by our banking, payment, communication and verification partners where necessary to provide NubiBooks.

6. Information relating to payment cards

Where card payment functionality is made available through NubiBooks, a customer may enter payment card information as part of the payment process.

Payment card information required to process the transaction may pass securely through our systems for transmission to the payment processor responsible for processing the card transaction.

Nubisoft does not use payment card information for purposes unrelated to processing the payment and does not intentionally retain full payment card numbers or card security codes as ordinary NubiBooks business records.

Card transactions may be processed by third-party payment processors. Those processors may process information in accordance with their own legal and regulatory obligations.

We continuously review our payment architecture and security controls having regard to applicable payment security requirements.

7. Identity and business verification

NubiBooks may require verification of a user's identity, business registration, directorship, bank account or other information before certain services are made available.

We may submit the information required for such verification to authorised verification service providers, banks or other appropriate partners.

The information returned from a verification may include confirmation information and other information necessary to determine whether the details supplied to us correspond with the relevant official or third-party records.

We may retain records showing that a verification was performed, the result of the verification and information reasonably required for compliance, fraud prevention, dispute resolution, security and audit purposes.

We may refuse or restrict access to a feature where required verification has not been completed or where information cannot reasonably be verified.

8. How we use personal data

We process personal data where there is a lawful basis for doing so.

Depending on the circumstances, we may process information because it is necessary to provide the service you requested, because we have a legal obligation, because we have a legitimate business or security interest that does not override your rights, because you have given consent, or because another lawful basis recognised under applicable law applies.

We may use personal data to create and maintain NubiBooks accounts; authenticate users; establish and manage businesses and branches; provide bookkeeping and accounting functionality; create and manage invoices, receipts, sales and expenses; manage products and stock; maintain customer and supplier records; provide business reports; verify identity and business information; provide payment and payout functionality; reconcile transactions; operate virtual accounts; prevent fraud and misuse; investigate security incidents; provide customer support; send transaction and service notifications; operate AI and voice features; improve reliability and performance; comply with legal and regulatory requirements; maintain financial and tax records; resolve disputes; enforce our agreements; and establish, exercise or defend legal claims.

We may also use information to understand and improve NubiBooks, provided that such use is lawful and proportionate.

Where consent is the appropriate lawful basis, you may withdraw that consent subject to applicable law.

How we measure our service

We record which campaign link brought you to NubiBooks (for example utm_source, utm_campaign and ad click IDs) and when you reach key steps: sign up, business set up, phone verified, first invoice and first payment. We keep this in our own systems to run and improve NubiBooks. It does not depend on cookies, and it is not shared with advertisers unless you allow ad measurement.

9. Customer information entered by merchants

A merchant may record personal information about its customers in NubiBooks.

The merchant is responsible for ensuring that it has a lawful reason to collect and use that information.

NubiBooks may process customer information in order to provide the services requested by the merchant.

This may include creating invoices and receipts, recording payments, generating business records, creating payment references, providing payment pages, sending invoices or receipts, sending payment confirmations, sending overdue invoice reminders where enabled, operating permitted WhatsApp communications and processing AI-assisted actions initiated by the merchant.

A communication sent to a merchant's customer in connection with a NubiBooks transaction may identify NubiBooks as the technology platform through which the communication or transaction is being processed.

We do not treat a merchant's customer database as our own marketing database merely because that information is stored in NubiBooks.

Where a customer wishes to correct information that a merchant entered into NubiBooks, the customer should ordinarily contact that merchant first. Where appropriate and lawful, Nubisoft will assist the merchant in responding to the request.

10. Artificial intelligence and voice features

NubiBooks provides optional artificial intelligence and voice-assisted features.

When you intentionally use these features, information you type or speak may be processed to understand your instruction and provide the requested result.

For example, you may instruct NubiBooks to assist with preparing an invoice, receipt, sale, expense, stock entry or another supported business record.

Voice input may be transmitted to a speech processing service for transcription or understanding. Text, including text generated from voice input, may also be transmitted to an artificial intelligence service provider where required to understand and process your request.

Depending on what you provide, this information may contain customer names, product information, transaction amounts and other business information.

NubiBooks may retain AI conversations, transcripts, prompts, generated drafts and related records where necessary to provide the service, maintain conversation history, troubleshoot errors, prevent abuse, improve reliability or satisfy legal obligations.

We do not intentionally record audio in the background.

Access to your microphone is intended to occur when you choose to use a voice feature and where your device and application support that functionality.

You should not provide passwords, bank PINs, one-time banking passwords or unrelated sensitive information through NubiBooks AI features.

Nubisoft may use third-party AI and speech service providers to provide these functions. Such providers receive information only to the extent reasonably necessary to provide the relevant service and subject to applicable contractual and legal safeguards.

AI-assisted functionality may prepare information or records for you. You remain responsible for reviewing business information and records generated or prepared using NubiBooks.

Voice recordings

When you use a voice feature, your recording is sent securely to our speech-to-text provider (OpenAI) to turn it into text. We do not store the recording itself: it is not saved to your chat history, our file storage or our logs. We keep the text it produced as part of your NubiBooks AI history, like a message you type. OpenAI processes the recording under its own terms and may keep it for a limited time for safety checks.

11. Automated processing

NubiBooks may use automated systems to perform ordinary technical, security, accounting, verification and business-management functions.

Where applicable law gives you rights concerning a decision based solely on automated processing that produces legal or similarly significant effects, those rights will be respected.

We will not represent an automated result as infallible, and we may provide appropriate means for review or correction where required by law and appropriate to the particular service.

12. Loan and credit related services

NubiBooks is principally a business management, accounting and payments platform.

Certain loan-related functionality may be displayed as unavailable, disabled, coming soon or otherwise not available for application at a particular time.

Where Nubisoft introduces, facilitates or makes available a credit or lending-related service, the applicable service will be provided subject to the regulatory approvals, partner arrangements, eligibility requirements, disclosures and additional terms applicable to that service at the relevant time.

Where a bank, financial institution or other licensed third party is the lender or financial service provider, that organisation may separately process information required to assess or provide the relevant financial service and its own privacy policy and regulatory obligations may apply.

We will update this Privacy Policy or provide an appropriate additional privacy notice where a new lending or credit-related service materially changes how personal data is processed.

13. Payments, virtual accounts and banking partners

NubiBooks may work with licensed banks, payment service providers and other financial service partners to provide payment, account, settlement and payout functionality.

Where you use these services, relevant information may be exchanged between Nubisoft and those partners.

This may include your name, business details, bank account information, transaction information, payment references, verification information and other information reasonably necessary to provide the service or satisfy applicable regulatory obligations.

A banking or payment partner may independently be required by law to retain or process information received in connection with a transaction.

Nubisoft cannot require an independent regulated institution to delete information that the institution is legally required to retain.

14. Communications and notifications

NubiBooks may send communications required to operate the Service.

These may include email verification messages, OTPs, security alerts, payment alerts, invoice and receipt communications, payment confirmations, payout information, account notices, support responses and other transactional communications.

Where a merchant has enabled an appropriate communication feature, NubiBooks may also facilitate communications with that merchant's customers through channels such as email or WhatsApp.

We may send push notifications to a user's device where notification permission has been granted.

Your device may display notification content on its lock screen. You are responsible for configuring your device notification settings according to your privacy preferences.

Marketing communications, where used, will be handled in accordance with applicable law. Where you have a right to opt out of a marketing communication, we will provide an appropriate means to do so.

Transactional, security, legal and essential service messages are not necessarily marketing communications and may continue while you maintain an account.

15. Device permissions

Certain NubiBooks mobile features may require permission to use capabilities available on your device.

Depending on your device, operating system, application version and the features available to you, these permissions may include notifications, microphone, camera and access to photographs or files selected by you.

Where a device permission is required, the relevant operating system may ask you to approve that permission.

You can manage device permissions through your device settings.

Disabling a permission may prevent the corresponding feature from working.

Nubisoft does not use permission to access a device feature for an unrelated purpose merely because the permission has been granted.

16. Cookies and similar technologies

NubiBooks uses cookies and similar browser or device storage where necessary to authenticate users, maintain sessions, protect accounts, remember appropriate settings and operate the Service.

We may also use local or session storage for limited application functions.

Some external services used by NubiBooks, including content delivery, mapping, font or other technical service providers, may receive technical information such as an IP address when your device connects to their service.

Where we introduce analytics, advertising or other tracking technologies that require additional notice or consent under applicable law, we will provide the required information and obtain consent where necessary.

Advertising and measurement cookies

We ask before using advertising cookies on nubibooks.ng and app.nubibooks.ng. When you first visit, you can choose Accept all, Manage choices or Continue without. Nothing for advertising loads until you choose.

Manage choices has two switches, both off until you turn them on:

• Measure our ads: we load tags from Meta (Facebook and Instagram), TikTok, Google (Analytics, Google Ads and YouTube) and LinkedIn. They tell us which of our ads bring people to NubiBooks, and whether those people sign up, set up a business, verify a phone, send a first invoice or receive a first payment.
• Personalised ads: Google may also use your visit to show you more relevant NubiBooks ads.

For Google we use Google Consent Mode. Until you allow it, Google's tags are told that advertising storage, analytics storage, sending user data for advertising and ad personalisation are all refused.

We send only the name of the step and the technical data your browser shares, such as device type and IP address. We never send your name, email, phone number, BVN, account details or amounts. If you came from one of our ads, we save the campaign details in the link (for example utm_campaign and ad click IDs) with your account.

We rely on your consent. If you choose Continue without, the tags do not load and NubiBooks works the same. You can change your choice at any time under Cookie settings. Our mobile apps do not use these advertising tags. These companies handle data under their own privacy policies and may process it outside Nigeria (see International transfers).

17. Information we do not intentionally collect

NubiBooks does not require access to your personal contacts, SMS messages or call history in order to provide its ordinary bookkeeping and payment services.

We do not intentionally listen to or record conversations in the background.

We will never ask you to provide your bank PIN, card PIN or internet banking password through ordinary NubiBooks support communications.

Nubisoft does not sell personal data as a business model.

You should not upload or enter sensitive personal information into NubiBooks unless it is necessary for a specific service and you are lawfully entitled to provide that information.

18. Disclosure of information

We do not disclose personal information indiscriminately.

We may disclose or provide access to personal data to service providers and partners where reasonably necessary to operate NubiBooks.

These may include cloud hosting and database providers, licensed banks, payment processors, identity and business verification providers, communication providers, email providers, push notification providers, artificial intelligence providers, speech processing providers, mapping and address services, tax or electronic invoicing infrastructure providers, professional advisers and other technical service providers required to operate the Service.

We may also disclose information where required by law, a court, a competent regulator, law enforcement authority or another public authority acting within its lawful powers.

We may disclose information where reasonably necessary to investigate fraud, protect our systems, protect the rights or safety of users, enforce an agreement or establish, exercise or defend a legal claim.

Where Nubisoft is involved in a merger, restructuring, investment, acquisition or transfer of all or part of its business, relevant information may be disclosed subject to appropriate confidentiality and data protection safeguards.

We may also disclose information where you expressly instruct or authorise us to do so.

19. Our service providers

Nubisoft uses third-party infrastructure and service providers to operate NubiBooks.

Depending on the service being used, information may be processed by providers involved in database hosting, application hosting, banking, payments, identity verification, communications, artificial intelligence, speech processing, push notifications, mapping, tax processing and other supporting services.

We assess the nature of information being shared and seek to use appropriate contractual, organisational and technical safeguards having regard to the nature of the processing and applicable law.

A service provider may have independent legal obligations concerning information that it processes, particularly where the provider is a regulated bank, payment company or verification provider.

20. International transfers of personal data

Some technology providers used by Nubisoft may process or store information outside Nigeria.

Where personal data is transferred outside Nigeria, Nubisoft will take reasonable steps to ensure that the transfer is carried out in accordance with applicable provisions of the Nigeria Data Protection Act and applicable guidance of the Nigeria Data Protection Commission.

Depending on the circumstances, this may involve an adequacy basis recognised by the Commission, contractual or other appropriate safeguards, a transfer necessary for the performance of a contract, consent where legally appropriate, or another lawful ground recognised under applicable law.

You may contact us for further information about safeguards applicable to international transfers of your personal data.

21. Information security

Nubisoft takes reasonable technical and organisational measures designed to protect personal data against accidental or unlawful loss, destruction, alteration, disclosure, misuse or unauthorised access.

Our security measures may include encryption in transit, authentication controls, access restrictions, role and permission controls, application-level business access controls, secure hosting, monitoring, logging and other measures appropriate to the nature of the information and the risks involved.

Access to business information is restricted according to account relationships and authorised user roles.

Users are responsible for protecting their passwords, devices and login information.

You must not share your password with another person.

If you believe that somebody has gained unauthorised access to your NubiBooks account, you should contact us immediately.

No internet-connected system can be guaranteed to be completely secure. Accordingly, while we take reasonable steps to protect information, we cannot guarantee that a security incident will never occur.

22. Data breaches and security incidents

Where Nubisoft becomes aware of a personal data breach, we will assess the nature and potential consequences of the incident.

Where applicable law requires notification to the Nigeria Data Protection Commission or affected data subjects, we will make the required notification within the period and in the manner prescribed by law.

Where notification to an affected person is required, we will provide information reasonably necessary to explain the nature of the incident and appropriate steps that the person may take.

We may also work with relevant banks, service providers, regulators, law enforcement authorities or security professionals where reasonably necessary to investigate and contain an incident.

23. Data retention

We retain personal data only for as long as reasonably necessary for the purpose for which it was collected or for another lawful purpose.

Different categories of information may therefore be retained for different periods.

Account information may generally be retained while an account remains active and for an appropriate period afterwards where necessary for security, dispute resolution, fraud prevention or compliance.

Financial, transaction, invoice, receipt, payment, payout, tax and accounting records may be retained after an account is closed where Nigerian law, regulatory obligations, audit requirements or legitimate legal purposes require continued retention.

Identity and verification records may also be retained where required for compliance, fraud prevention, regulatory, audit or legal purposes.

Security logs, IP records and technical records may be retained for periods reasonably necessary for security, fraud prevention, troubleshooting, audit or legal compliance.

Information processed by third-party providers may be subject to their applicable retention obligations, particularly where they act as independent regulated entities.

Where information is no longer required and there is no lawful reason to retain it, we will take reasonable steps to delete, anonymise or otherwise securely dispose of it.

24. Account deletion

An account owner or other eligible user may request deletion of their NubiBooks account through an available account deletion function or by contacting Nubisoft.

Before an account containing funds or transactions can be fully closed, outstanding transactions, payouts or balances may need to be resolved.

Account deletion does not necessarily mean that every record associated with the account is immediately erased from every system.

When an account is deleted, we may remove or anonymise personal information that is no longer required while retaining information that we are required or permitted by law to keep.

For example, financial, payment, accounting, tax, compliance, security, fraud prevention, audit and dispute records may need to remain after an account has been closed.

Information may also remain temporarily in backups, system logs, email records or the systems of third-party service providers until it is deleted in accordance with applicable retention arrangements.

Where an independent bank, payment provider, verification provider or other regulated organisation has received information in connection with providing its own service, its independent legal retention obligations may continue after your NubiBooks account is deleted.

We will not retain identifiable personal data indefinitely merely because an account once existed where there is no continuing lawful reason for retaining it.

25. Your data protection rights

Subject to the Nigeria Data Protection Act and any applicable limitations or exceptions, you may have rights in relation to personal data that Nubisoft holds about you.

These may include the right to receive information about the processing of your personal data, request access to personal data held about you, request correction of inaccurate or incomplete information, request deletion where there is no lawful basis for continued retention, request restriction of processing in appropriate circumstances, object to certain processing, request data portability where applicable, withdraw consent where processing is based on consent, and raise concerns regarding qualifying automated decision-making.

You also have the right to lodge a complaint with the Nigeria Data Protection Commission where applicable.

These rights are not absolute.

For example, we may be unable to delete a transaction record where we are legally required to retain that record. We may also need to verify your identity before responding to a request so that personal information is not disclosed to an unauthorised person.

We will respond to valid requests within the period required by applicable law.

26. Data relating to children

NubiBooks is designed as a business and commercial service and is not intended to be used independently by children.

A person who creates and controls a NubiBooks business account should be legally capable of entering into the applicable agreement for the Service.

We do not knowingly design NubiBooks for the collection of children's personal data.

If we become aware that personal information relating to a child has been provided to us in circumstances where it should not have been collected or processed, we will take appropriate steps having regard to applicable law and the circumstances of the processing.

27. Your responsibilities

You are responsible for ensuring that information you provide to NubiBooks is accurate and that you have the right to provide personal information relating to another person.

If you operate a business account and enter information about your customers, staff, suppliers or other persons, you are responsible for complying with applicable privacy and data protection obligations relating to your collection and use of that information.

You must not use NubiBooks to collect information unlawfully or for an unlawful purpose.

You must take reasonable steps to protect your login credentials and restrict staff access according to the needs of your business.

28. Changes to this Privacy Policy

NubiBooks will continue to develop, and our privacy practices may change as we introduce new products, service providers or functionality or as applicable law changes.

We may amend this Privacy Policy from time to time.

Where we make a material change, we may notify users through NubiBooks, by email or through another appropriate communication channel.

The date shown at the beginning of this Privacy Policy indicates when the Policy was last updated.

Continued use of NubiBooks after an updated Privacy Policy becomes effective will be subject to applicable law and any consent requirements that may apply to a particular change.

29. Contacting Nubisoft about privacy

Questions, requests or complaints concerning this Privacy Policy or the processing of personal data may be sent to:

Data Protection Team
Nubisoft Limited
Magodo Phase 2, Lagos, Nigeria
Email: hello@nubisoft.ng

Please include enough information for us to understand your request.

For your protection, we may need to verify your identity before giving access to personal information or making certain changes to an account.

Please do not send your password, bank PIN, card PIN or one-time banking password to us.

30. Complaints to the Nigeria Data Protection Commission

We encourage you to contact Nubisoft first where you have a concern about how your personal data has been handled so that we can investigate and attempt to resolve the matter.

You also have the right, where applicable, to make a complaint to the Nigeria Data Protection Commission.

Making a complaint does not affect any other right or remedy available to you under applicable law.

31. General

If any provision of this Privacy Policy is found to be invalid or unenforceable, that will not necessarily affect the validity of the remaining provisions.

This Privacy Policy concerns the handling of personal data. Other aspects of your use of NubiBooks may be governed by the NubiBooks Terms and Conditions and any additional terms applicable to a particular service.

Where a particular regulated product or service requires an additional privacy notice, consent or disclosure, that additional notice may apply together with this Privacy Policy.

This Privacy Policy is governed by applicable laws of the Federal Republic of Nigeria.

Nubisoft Limited
NubiBooks
Magodo Phase 2, Lagos, Nigeria
hello@nubisoft.ng
Effective Date: 2 October 2026