Effective Date: August 28, 2026
1. Introduction
QAS Trust Ltd (“QAS Trust,” “we,” “our,” or “us”) is committed to protecting your privacy and handling your personal data responsibly.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you access or use the QASPay mobile application and related services (collectively, the “Services”).
This Policy is issued in accordance with the Nigeria Data Protection Act 2023 (“NDPA”), its subsidiary regulations and guidelines, and applicable Central Bank of Nigeria (“CBN”) directives, including Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) requirements.
2. Definitions
“Personal Data” means any information relating to an identified or identifiable individual.
“Data Controller” means QAS Trust Ltd, which determines the purposes and means of processing your Personal Data.
“Data Processor” means a third party that processes Personal Data on our behalf and under our instructions.
“Data Subject” means you, the individual to whom the Personal Data relates.
“Processing” means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
3. Information We Collect
We collect the following categories of information:
- Personal Data: Full name, email address, phone number, and date of birth; Residential address.
- Identity Data: Bank Verification Number (BVN) and National Identity Number (NIN); Government-issued identification, including National ID, International Passport, Driver’s License, and Voter’s Card; Biometric data, including a liveness selfie, used solely for identity verification.
- Financial Data: Transaction history and linked bank account details; SaveRite contribution history, frequency, and accrued Return on Savings (ROS).
4. Legal Basis and Purpose of Processing
We process your Personal Data on the following lawful bases under the NDPA.
- Identity verification and KYC compliance: Legal/regulatory obligation (CBN guidance)
- Processing transactions, including wallet funding, bill payments, withdrawals, and SaveRite contributions: Performance of contract
- Calculating ROS, QASPoints, and cashback: Performance of contract
- Transactional communications and service notifications: Performance of contract / legitimate interest
- Customer support: Performance of contract
- Fraud prevention and unauthorized access monitoring: Legitimate interest / legal obligation
- Marketing communications: Consent
- Compliance with NDPA, CBN AML rules, and other applicable law: Legal obligation
5. Data Sharing and Third Parties
QAS Trust Ltd does not sell your Personal Data.
We share Personal Data only where necessary, and only with parties bound by appropriate confidentiality, security, and data protection obligations.
6. Cross-Border Data Transfers
Where your Personal Data is transferred to, stored in, or processed by service providers located outside Nigeria, we take steps to ensure it receives a level of protection adequate and comparable to that available under the NDPA.
7. Data Security
We implement technical and organizational measures designed to protect your Personal Data, including:
- Encryption of data in transit and at rest using industry-standard protocols
- Secure hashing of your Transaction PIN to ensure QAS Trust staff do not have access to it
- Role-based access controls restricting internal access to Personal Data
- Continuous transaction monitoring to detect and flag unusual activity
- Regular security testing and audit logging
8. Data Segregation
Funds and records associated with your cooperative or savings activity, including SaveRite, are maintained on segregated ledgers, distinct from your QASPay Operational Wallet data.
9. Data Retention
We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, tax, or accounting requirements.
10. Your Rights as a Data Subject
At any point while we are in possession of or processing your Personal Data, you have the right to:
- Withdraw your consent at any time for processing based on consent, such as marketing communications
- Request access to a copy of the Personal Data we hold about you
- Correct Personal Data that we hold about you that is inaccurate or incomplete
- Request erasure of Personal Data we hold about you, where applicable
- Restrict our processing activities relating to your data in certain circumstances
- Request data portability where technically feasible
- Object to certain types of processing, such as direct marketing
- Object to automated processing, including profiling
11. Data Protection Officer
Our Data Protection Officer can be contacted with any questions or concerns regarding this Policy or our data processing practices.
Name: Ibrahim Akindele
Email: Akindele.oluwaseye@qastrust.com
Phone Number: 09035133628
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, products, or applicable legal requirements.
Where appropriate, we will communicate material changes through the QASPay application or other appropriate channels.
13. Contact Us
If you have any questions about this Privacy Policy or how we handle your Personal Data, please contact us at:
Email: contact@qastrust.com
Note: This document is scoped specifically to QASPay for in-app display.
The full QAS Trust Ltd Privacy Policy, which also covers Private Capital Placement, QAS Travels, and QAS Foundation, is available at qastrust.com/privacy.