Privacy Policy

This Privacy Policy explains how 2Settle ("2Settle", "we", "us") collects, uses, discloses, and protects personal data when you use our service to send, receive, and spend crypto with instant fiat conversion. It applies to our web app, Telegram integration, and API-based integrations with partners.

2Settle is operated by 2SettleHQ, the data controller for the purposes of this policy, registered at Plot 690, Idris Gadoda Street, Wuye, Abuja.

1. Data We Collect

We collect the following categories of personal data:

• Identity & contact data: email address or phone number (used for one-time-code login), name associated with a bank account when receiving a payout, Telegram account details if you use our Telegram integration.
• Financial & transaction data: fiat amounts and currency, crypto amounts and network, deposit addresses, exchange rates, receiver bank name, account number, and account name, and transaction status/history.
• Wallet data: your crypto wallet address, if you sign in or transact using a connected wallet.
• Technical data: IP address, device/browser information, and request metadata, collected automatically as part of our security and audit logging.

We do not collect or store card payment data (e.g. card number, CVV); card payments are not supported on this platform.

2. How We Use Your Data

• To process and settle your transfers, gifts, payment requests, and payouts
• To authenticate you (one-time codes, wallet-signature login, Google Sign-In) without ever storing a password
• To detect and prevent fraud, and to secure our platform (rate limiting, audit logging, deposit monitoring)
• To communicate with you about your transactions or account
• To comply with legal, regulatory, and financial recordkeeping obligations

3. Legal Basis for Processing

We process your data on the basis of: performance of a contract (processing the transaction you requested), compliance with a legal obligation (financial recordkeeping), and legitimate interest (fraud prevention and platform security). Where required, we rely on your consent, for example when linking an additional login method to your account.

4. Who We Share Data With

We share data only where necessary to complete your transaction or run the service:

• Settlement and payout partners, to complete a bank transfer on your behalf
• Blockchain networks, inherently public once a transaction is broadcast on-chain
• Service providers who support our infrastructure (hosting, exchange-rate data)

We do not sell your personal data. Any partner receiving data on our behalf is required to protect it to a standard consistent with this policy, transmitted only over encrypted connections and never shared beyond what is needed to complete your request.

5. How We Protect Your Data

• Sensitive credentials (API secrets, one-time codes, session tokens) are never stored in plaintext, only as cryptographic hashes
• Wallet key material is encrypted at rest and only decrypted in memory when needed
• All data in transit is protected with TLS encryption
• Access to production systems and data is limited, logged, and reviewed regularly

6. How Long We Keep Your Data

Financial and transaction records are retained for a minimum of 5 years, consistent with standard financial recordkeeping expectations for payment businesses. Technical security logs are retained for 12 months on a rolling basis. Data is deleted or anonymized once it is no longer needed for these purposes, unless a longer period is required by law.

7. Your Rights

Subject to applicable law (including the Nigeria Data Protection Act/NDPR, and GDPR where it applies to you), you have the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data, where we are not required to retain it for legal or financial recordkeeping reasons
• Withdraw consent, where processing is based on consent

To exercise any of these rights, contact us at compliance@2settle.io. We will respond within the timeframe required by applicable law.

8. Children's Privacy

Our service is not directed to individuals under the age of 18, and we do not knowingly collect personal data from minors.

9. Changes to This Policy

We may update this policy as our service evolves. Material changes will be reflected by updating the "Last updated" date above.