Last Updated: October 2026 • Version 2.4 • Effective for all Nigerian and international users
Commitment to Your Privacy & NDPC Compliance
HARPS Escrow Limited (“HARPS”, “we”, “our”, or “us”) is an institutional peer-to-peer safe deal platform incorporated in Nigeria. We are committed to protecting the privacy, security, and integrity of your personal information in accordance with the Nigeria Data Protection Act 2023 (NDPA), the General Data Protection Directives issued by the Nigeria Data Protection Commission (NDPC), and applicable Central Bank of Nigeria (CBN) regulations.
1Categories of Personal Data We Collect
We collect only the minimum personal data strictly necessary to operate our safe marketplace, fulfill escrow contracts, prevent payment fraud, and disburse wallet payouts:
Identity Data: Full legal name, seller display name, and profile images (avatar and cover banner).
Contact Data: Verified email address and WhatsApp telephone number for transaction milestones and deal communication.
Financial & Payout Data: 10-digit Nigerian NUBAN bank account number, account holder name, and CBN bank code for processing wallet withdrawals. Note: HARPS never collects, handles, or stores debit/credit card numbers or CVVs. All card transactions are processed through CBN-licensed, PCI-DSS Level 1 compliant processors (Paystack).
Verification & KYC Data: Verification status indicators (NIN/BVN identity resolution status performed via licensed identity verification services). Raw national identity numbers are never stored in plain text.
Technical & Usage Data: IP address, device identifier, browser type, operating system, and push notification tokens (OneSignal).
2Lawful Basis for Processing (NDPA Section 25)
Under Section 25 of the Nigeria Data Protection Act 2023, we process your personal data under the following lawful bases:
Contractual Necessity
Processing required to create escrow safe deals, lock funds, verify deliveries, and disburse payout earnings to your bank account.
Legal Obligation
Compliance with statutory Nigerian Anti-Money Laundering (AML/CFT) laws, tax reporting, and anti-fraud mandates.
Legitimate Consent
Freely given consent for web push notifications, optional public profile displays, and marketing broadcasts.
3Data Retention Schedules & Statutory Limits
We retain personal data strictly for as long as necessary to fulfill the purposes for which it was collected, or as required by Nigerian law:
Escrow & Financial Ledger Records: Retained for a mandatory statutory period of five (5) years following transaction completion, in full compliance with the Money Laundering (Prevention and Prohibition) Act 2022 and CBN Record Keeping Guidelines.
User Account Profiles: Retained for the duration of an active account. Upon verified request for account termination, non-financial profile information is securely anonymized or permanently purged within 30 days.
Audit Logs & Security Trails: Maintained for three (3) years to mediate prospective disputes, investigate fraudulent activity, and comply with law enforcement inquiries.
4Third-Party Data Processors & Security
We do not sell, rent, or trade your personal data. We engage only reputable, ISO-certified, and CBN-licensed service providers bound by strict Data Processing Agreements (DPAs):
For questions regarding this policy, to lodge a data subject access or deletion request, or to raise a data protection concern, please contact our designated Data Protection Officer:
