1. Who controls your data
3PLE A DATA LIMITED (RC 9746103), trading as 3pple A, of Office No. 108 Karkasara Road, Tarauni LGA Kano, Kano State, Nigeria, Kano State, is the data controller. Our Data Protection Officer can be reached at privacy@3plea.com.ng.
We process personal data under the Nigeria Data Protection Act 2023 and the regulations made under it.
2. What we collect and why
| What | Why | How long |
|---|---|---|
| Name, phone number, email | To create your account, verify it by OTP, and send you receipts | While your account is open, then 7 years |
| Transaction PIN (hashed) | To authorise every debit from your wallet | While your account is open |
| Wallet and ledger records | To keep an accurate balance and prove what happened to your money | 7 years after the transaction |
| Recipient numbers and meter numbers | To deliver what you bought and to let you save beneficiaries | 7 years after the transaction |
| Device token | To send push notifications you have enabled | Until you sign out or disable them |
| IP address and device details | To detect fraud, abuse and duplicate-device referral farming | 12 months |
What we deliberately do not collect
- Card numbers. Card payments are handled entirely by our payment partner. Card details never reach our servers.
- Your PIN or password in readable form. Both are stored as one-way hashes. We cannot read them, and neither can anyone who obtained a copy of our database.
- Your contacts, photos, location or SMS. The app does not ask for them.
3. Our lawful bases
- Performance of a contract. Everything needed to run your wallet and deliver what you buy.
- Legal obligation. Anti-money-laundering checks and keeping financial records.
- Legitimate interest. Fraud prevention, abuse detection, and keeping the service secure and working.
- Consent. Marketing messages and push notifications. You can withdraw it at any time without losing access to the service.
4. Who we share it with
We share the minimum needed, and only with:
- Our payment processor, to take your funding and to open your dedicated account.
- Service aggregators, who receive the recipient number or meter number needed to deliver what you bought, and nothing about your wallet.
- Our SMS provider, which receives your phone number to deliver one-time codes and transaction alerts.
- Regulators and law enforcement, where we are legally required to.
We do not sell your data, and we do not share it with advertisers or data brokers.
5. Where your data lives
Our database runs on servers we control. Some of our processors operate outside Nigeria; where data is transferred abroad we rely on the transfer mechanisms permitted by the NDPA and require the same standard of protection contractually.
6. How we protect it
- Traffic between your device and us is encrypted in transit.
- Passwords and PINs are hashed with bcrypt and are not recoverable.
- Staff access to the back office is role-limited and every action is written to an audit log.
- Deactivating a staff account ends its access immediately, not when their session expires.
7. Your rights
Under the NDPA you can ask us to:
- Give you a copy of the personal data we hold about you.
- Correct anything inaccurate.
- Delete your data, where we are not required to keep it for financial record-keeping.
- Stop using it for marketing, which you can also do yourself in the app.
- Object to processing based on legitimate interest.
Email privacy@3plea.com.ng. We will respond within 30 days. If you are not satisfied you can complain to the Nigeria Data Protection Commission.
One honest limit: we cannot delete the ledger entries behind completed transactions, because we are required to keep financial records. We can delete the profile attached to them.
8. Cookies
This website uses no advertising or tracking cookies. Signing in stores a session token in your browser’s local storage so you stay signed in; clearing your browser data signs you out.
9. Children
The service is not for anyone under 18. If we learn that an account belongs to a child we will close it and delete the data we are not required to keep.
10. Changes
Updates appear here with a new date. If a change materially affects how we use your data we will tell you in the app or by email before it takes effect.