Effective Date: October 2026

TREDES LIMITED (“TREDES”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you use the TREDES website, mobile application, digital platforms, products and services.

This Policy is intended to operate in accordance with applicable Nigerian data protection laws and regulatory requirements.

1. ABOUT TREDES

TREDES LIMITED is a diversified Nigerian company providing, among other services, technology-enabled financial solutions through the TREDES platform.

TREDES is not a bank. Regulated banking and payment services available through the TREDES platform are provided or supported through duly licensed and authorised financial institutions and service providers.

2. INFORMATION WE MAY COLLECT

Depending on the services you use, we may collect the following information:

Personal and Contact Information

  • Full name;
  • Telephone number;
  • Email address;
  • Residential or business address;
  • Date of birth;
  • Gender, where required;
  • Photograph; and
  • Other identification details.

Identity and KYC Information

  • Bank Verification Number (BVN);
  • National Identification Number (NIN);
  • Government-issued identification;
  • Facial image and biometric verification information, where applicable;
  • Business registration information; and
  • Other information required for identity verification, fraud prevention, risk management or regulatory compliance.

FINANCIAL AND TRANSACTION INFORMATION

  • TREDES account and wallet information;
  • Virtual account details;
  • Transaction history;
  • Payment information; and
  • Other information relating to products and services used through TREDES.

Device and Technical Information

We may collect information including:

  • Device type;
  • Operating system;
  • IP address;
  • Device identifiers;
  • Login information;
  • Application activity; and
  • Security and fraud-prevention information.

We will only request device permissions reasonably necessary for providing, protecting or improving our services in accordance with applicable requirements.

3. HOW WE COLLECT INFORMATION

We may collect personal information:

  • Directly from you;
  • Through the TREDES website or mobile application;
  • During account registration and onboarding;
  • During identity verification or KYC;
  • When you perform transactions;
  • From authorised identity-verification providers;
  • From licensed financial institutions and service providers;
  • From legally accessible identity or regulatory databases; and
  • Through customer-support interactions.

4. HOW WE USE YOUR INFORMATION

TREDES may process your personal information to:

  • Create and manage your TREDES account;
  • Verify your identity;
  • Provide requested products and services;
  • Process payments and transactions;
  • Assess service eligibility and risk;
  • Prevent, detect and investigate fraud;
  • Carry out Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF) and other compliance activities;
  • Protect our customers, systems and platforms;
  • Provide customer support;
  • Communicate transaction and service information;
  • Improve our products and services;
  • Meet legal and regulatory obligations; and
  • Send marketing communications where permitted and subject to your preferences.

5. LAWFUL BASIS FOR PROCESSING

TREDES will process personal information only where there is an appropriate lawful basis.

Depending on the circumstances, this may include:

  • Your consent;
  • Performance of a contract or provision of a requested service;
  • Compliance with a legal or regulatory obligation;
  • Legitimate interests;
  • Protection of vital interests; or
  • Any other lawful basis recognised under applicable Nigerian data protection law.

6. IDENTITY VERIFICATION AND KYC

TREDES may use authorised third-party identity-verification services to verify information including your BVN, NIN, facial identity, business information and other information required for KYC and compliance purposes.

Such service providers may process relevant information on our behalf or as otherwise permitted by applicable law.

TREDES may restrict access to certain services where identity information cannot be verified or where reasonable security, fraud, legal or compliance concerns arise.

7. FINANCIAL INSTITUTIONS AND SERVICE PROVIDERS

Where necessary to provide regulated banking, payment or related services, TREDES may share relevant information with duly licensed and authorised financial institutions and service providers.

Where specifically applicable, information necessary for providing virtual account services may be shared with Wema Bank PLC, which provides the underlying virtual account infrastructure.

This service arrangement does not constitute a legal partnership between TREDES and Wema Bank PLC.

8. WHEN WE MAY SHARE PERSONAL INFORMATION

TREDES may share necessary personal information with:

  • Licensed financial institutions;
  • Payment processors and switching providers;
  • KYC and identity-verification providers;
  • Telecommunications and bill-payment service providers;
  • Technology and infrastructure providers;
  • Professional advisers;
  • Regulatory, government or law-enforcement authorities where legally required; and
  • Other service providers reasonably necessary for delivering TREDES services.

We require appropriate handling and protection of personal information by service providers where applicable.

TREDES does not sell customers’ personal information.

9. MARKETING COMMUNICATIONS

Where permitted, TREDES may send you information about products, services, promotions and other relevant offers.

You may opt out of marketing communications through the available unsubscribe or preference-management channels.

Transaction, security, service or regulatory communications may still be sent where necessary.

10. COOKIES AND SIMILAR TECHNOLOGIES

The TREDES website and digital platforms may use cookies and similar technologies for purposes including:

  • Essential website functionality;
  • Security;
  • Remembering user preferences;
  • Analytics; and
  • Improving user experience.

Where consent is legally required, appropriate choices will be provided.

11. DATA RETENTION

TREDES retains personal information only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, regulatory, accounting, fraud-prevention, compliance and dispute-resolution requirements.

Where information is no longer required, it may be securely deleted, anonymised or otherwise managed in accordance with applicable requirements.

12. DATA SECURITY

TREDES maintains appropriate technical and organisational safeguards designed to protect personal information against unauthorised access, misuse, loss, alteration, disclosure or destruction.

These measures may include appropriate access controls, encryption, system monitoring, authentication and other security measures.

No electronic system can be guaranteed to be completely secure. Customers are also responsible for protecting their devices, passwords, PINs, OTPs and other account credentials.

13. INTERNATIONAL DATA TRANSFERS

Where personal information needs to be processed or stored outside Nigeria, TREDES will take appropriate steps to ensure that the transfer is carried out in accordance with applicable Nigerian data protection requirements.

14. YOUR PRIVACY RIGHTS

Subject to applicable law, you may have the right to:

  • Be informed about how your personal information is processed;
  • Request access to your personal information;
  • Request correction of inaccurate or incomplete information;
  • Request deletion where legally applicable;
  • Restrict certain processing;
  • Object to certain processing;
  • Withdraw consent where processing is based on consent;
  • Request data portability where applicable;
  • Seek appropriate review in relation to certain automated decisions; and
  • Lodge a complaint with the appropriate data protection authority.

Some rights may be subject to legal, regulatory or operational limitations.

15. CHILDREN’S PRIVACY

TREDES services are not intended for persons who do not meet the applicable minimum age or legal requirements for the relevant service, except where a service is expressly designed and lawfully structured for such persons.

Where parental or guardian consent is required by law, appropriate steps will be taken before processing the relevant information.

16. THIRD-PARTY LINKS AND SERVICES

The TREDES website or application may contain links to or integrations with third-party websites, platforms or services.

Those third parties may operate under their own privacy policies and terms. TREDES is not responsible for the privacy practices of independent third parties.

We encourage users to review the applicable privacy policies before providing personal information.

17. AUTOMATED DECISION-MAKING

Where automated systems are used in areas such as fraud detection, risk assessment, TREDES will use such systems in accordance with applicable legal and data-protection requirements.

Where applicable, customers may have rights relating to certain decisions made solely through automated processing.

18. CHANGES TO THIS PRIVACY POLICY

TREDES may update this Privacy Policy from time to time to reflect changes in:

  • Applicable laws or regulations;
  • Our products and services;
  • Technology;
  • Security practices; or
  • Our data-processing activities.

Where appropriate, material changes will be communicated through the TREDES website, mobile application or other suitable channels.

19. PRIVACY COMPLAINTS AND ENQUIRIES

If you have questions, concerns or complaints about how TREDES handles your personal information, please contact us through our official support or privacy channels.

We will endeavour to investigate and respond to privacy-related concerns in accordance with applicable requirements.

You may also have the right to lodge a complaint with the appropriate Nigerian data protection authority.

20. CONTACT US

For privacy enquiries, data-access requests or other matters relating to this Privacy Policy, please contact us through the official channels published on:

www.tredes.com.ng

TREDES LIMITED
27 Otukoya Street, Asolo Bus Stop, Owutu, Agric, Ikorodu, Lagos State, Nigeria.