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Privacy Policy

Your Privacy Matters to Us

Effective Date: March 19, 2026  | Last Updated: March 19, 2026

SAW Technologies Limited ("we," "us," "our," or "the Company") operates the Cirva mobile application and related services (collectively, "Cirva" or "the Service"). This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use Cirva.

By creating an account or using Cirva in any way, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described below.

1. Information We Collect

1.1 Information You Provide Directly

When you register for and use Cirva, we collect the following information:

  • Account Information: Full name, email address, phone number, password, and profile picture.
  • Identity Verification: Bank Verification Number (BVN) for the purpose of verifying your identity and enabling withdrawals and bank transfers.
  • Financial Information: Bank account details, card details for funding your wallet, and transaction PIN.
  • Savings and Group Data: Savings plan details, contribution amounts, group memberships, payout preferences, and loan requests.
  • Communications: Messages sent within group chats, support ticket submissions, and any correspondence with our support team.
  • Bill Payment Information: Beneficiary details such as phone numbers, meter numbers, smart card numbers, and decoder IDs saved for bill payment services.
1.2 Information We Collect Automatically
  • Device Information: Device type, operating system, unique device identifiers, and mobile network information.
  • Usage Data: Features accessed, pages viewed, actions taken within the app, timestamps, and session duration.
  • Transaction Records: Records of all financial transactions including deposits, withdrawals, transfers, contributions, loan disbursements, repayments, and bill payments.
  • Authentication Data: Login timestamps, IP addresses, biometric authentication events (we do not store your biometric data — authentication is handled locally on your device).
  • Push Notification Tokens: Firebase Cloud Messaging tokens for delivering notifications to your device.
1.3 Information from Third Parties

We may receive information about you from third-party services including Paystack (payment confirmation details, card authorization tokens), Kuda Bank (account verification details and transfer confirmations), and Firebase (authentication credentials if you sign in using Google or Apple ID).

2. How We Use Your Information

  • Account Management: To create and maintain your account, verify your identity, and authenticate your access.
  • Financial Services: To process contributions, payouts, wallet funding, withdrawals, transfers, loan disbursements, repayments, and bill payments.
  • Group Operations: To manage group memberships, track contribution schedules, calculate rotational payouts, and facilitate group chat.
  • Savings Tracking: To monitor your savings progress, enforce locked savings terms, and notify you about milestones and maturity dates.
  • Loan Processing: To evaluate loan requests, calculate interest and repayment schedules, process disbursements, and send repayment reminders.
  • Bill Payments: To process airtime, data, cable TV, electricity, internet, and other utility payments on your behalf.
  • Notifications: To send transaction alerts, contribution reminders, payout notifications, and other service-related communications.
  • Customer Support: To respond to your inquiries, resolve disputes, and manage support tickets.
  • Security and Fraud Prevention: To detect and prevent unauthorized access, fraud, and other harmful activities.
  • Service Improvement: To analyze usage patterns, fix bugs, and improve performance and functionality.
  • Legal Compliance: To comply with applicable laws, regulations, and lawful requests from authorities.

3. How We Store and Protect Your Information

3.1 Data Storage

Your data is stored on secure servers hosted by our infrastructure providers with restricted access controls.

3.2 Security Measures
  • Encryption: Sensitive financial data is encrypted using AES-256 at rest. All data in transit is encrypted using TLS/SSL.
  • Authentication: Access is protected by password, transaction PIN, and optional biometric authentication. Biometric data never leaves your device.
  • Access Controls: Internal access is restricted to authorized personnel on a need-to-know basis.
  • Rate Limiting: API requests are throttled to prevent abuse.
  • Account Protection: Accounts are temporarily suspended after multiple failed login or PIN attempts.
3.3 Data Retention

We retain your personal information for as long as your account remains active or as needed to provide services. Transaction records and financial data may be retained for a minimum of six (6) years in accordance with applicable financial regulations.

4. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including Paystack (payment processing), Kuda Bank (fund transfers), VTU.ng (bill payments), Termii (SMS delivery), ZeptoMail/Resend (email delivery), Firebase (authentication, push notifications), and Cloudinary (profile image storage).

4.2 Group Members

When you join a savings group, your display name, profile picture, and contribution status are visible to other members. Your financial details such as wallet balance, BVN, bank account information, and personal contact details are never shared with other group members.

4.3 Legal and Regulatory Disclosure

We may disclose your information if required by law, regulation, or legal process, or to protect the rights, property, or safety of SAW Technologies Limited, our users, or the public.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change.

5. Your Rights and Choices

  • Access: View your personal information through your Cirva account settings.
  • Correction: Update your profile information directly within the app.
  • Deletion: Request deletion of your account and associated data by contacting support.
  • Withdrawal of Consent: Withdraw consent to certain data processing activities.
  • Data Portability: Request a copy of your personal data in a machine-readable format.
  • Notification Preferences: Manage push notification and email preferences through app and device settings.
  • Biometric Opt-Out: Disable biometric authentication at any time without affecting service access.

To exercise any of these rights, contact us at sawtechnologieslimited@gmail.com.

6. Cookies and Tracking

The Cirva mobile application does not use browser cookies. However, our website and admin dashboard may use cookies and similar technologies to maintain sessions and improve user experience. You can control cookie preferences through your browser settings.

7. Children's Privacy

Cirva is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete that information promptly.

8. International Data Transfers

Your information may be transferred to and processed in countries other than the country in which you reside. By using Cirva, you consent to the transfer of your information to these jurisdictions, where data protection laws may differ from those in your country.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the app or by email before the changes take effect. Your continued use of Cirva after the effective date constitutes your acceptance of the changes.

10. Data Protection Compliance

SAW Technologies Limited is committed to complying with the Nigeria Data Protection Act (NDPA) 2023 and the Nigeria Data Protection Regulation (NDPR). We process personal data lawfully, fairly, and transparently. If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

SAW Technologies Limited
Email: sawtechnologieslimited@gmail.com