Privacy Policy

We may collect:

1.1 Personal Information

• Full name and date of birth.
• Contact details, including email address and phone number.
• Residential address.
• Bank account details.
• Government-issued identification documents.
• Bank Verification Number (BVN), National Identification Number (NIN), and associated verification information, where required.

1.2 Transaction Information

• Cryptocurrency wallet addresses.
• Transaction amounts, timestamps, and references.
• Exchange rates used.
• Payment details and transaction status.
• Records of services used through Greatiby.

1.3 Technical Information

• Device type and operating system.
• IP address.
• Browser type and settings.
• Usage and activity information relating to our platform.

1.4 Tier 2 Facial Verification and TrueDepth

Greatiby uses Smile ID and Dojah as our third-party identity verification partners. These providers support identity verification, facial matching, and liveness checks.

During Tier 2 verification, Smile ID or Dojah, depending on the applicable verification process, accesses your device’s camera and, on supported Apple devices, its TrueDepth functionality.

This allows the applicable provider to capture and process facial information to check that a real person is completing the verification and that the person matches the relevant identification records. The purpose is to verify identity and prevent impersonation or fraudulent use of another person’s identification.

Within our identity verification process, this camera and TrueDepth access takes place during Tier 2 verification.

Greatiby does not retain the selfie or TrueDepth images captured during this verification process. The applicable verification provider processes the captured information, and Greatiby uses the verification outcome to determine whether the account meets the relevant verification requirements.

1.5 Apple Face ID Authentication

Apple Face ID authentication is separate from the facial identity verification performed by Smile ID and Dojah.

If you enable Face ID for Greatiby on a supported Apple device, Apple performs the authentication on your device. Greatiby receives the authentication result and cannot access the facial data enrolled in Apple Face ID.

Apple’s Face ID data remains protected on your device. Greatiby does not store or share that enrolled facial data.

You can manage or disable Face ID access through your device settings. Further information is available in Apple’s Face ID privacy information.

We use personal information to:

• Create, manage, and verify your account.
• Comply with applicable Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements.
• Process cryptocurrency exchanges, transfers, payments, and other services you request.
• Detect and prevent fraud, impersonation, unauthorised access, and illegal activity.
• Respond to support requests.
• Communicate with you about your account, transactions, and service updates.
• Improve the functionality, reliability, and security of our platform.

The facial verification process provided through Smile ID or Dojah is used to confirm identity and liveness and prevent identity fraud.

We do not use facial verification information for advertising, marketing, or tracking users across unrelated applications or websites. We do not sell or rent this information.

Where processing relies on consent, you may withdraw that consent. If required identity verification cannot be completed, features that depend on that verification may remain unavailable.

We may share relevant personal information with:

• Smile ID and Dojah, as applicable, to perform identity verification, facial matching, and liveness checks.
• Payment processors, banking partners, and other providers needed to deliver the services you request.
• Technology and security providers that support our platform.
• Regulatory authorities, law enforcement agencies, or other parties where disclosure is legally required.

We limit sharing to information relevant to the purpose of the disclosure. The verification provider used depends on the applicable verification process.

Each provider’s handling of verification information is subject to the applicable data processing arrangements and privacy policies.

We do not sell or rent your personal information.

The identity verification services provided by Smile ID and Dojah are separate from Apple Face ID authentication. Using Apple Face ID to authenticate access to Greatiby does not give either provider access to the facial data enrolled in Apple Face ID.

We take appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration, or disclosure.

Access to information is restricted according to the responsibilities of the personnel and service providers handling it. No method of electronic transmission or storage can guarantee absolute security.

4.1 TrueDepth API & Facial Information Disclosure

Facial information captured during Tier 2 verification is processed through the applicable provider, Smile ID or Dojah.

Greatiby does not retain copies of the selfie or TrueDepth images captured during this verification process in its account records or on its servers.

4.1.1. Smile ID SDK (iOS)

Information Processed: The Smile ID SDK uses Apple’s TrueDepth API via ARKit on every selfie capture to calculate 3D spatial orientation and facial expressions (blend shapes).

Data Transmission & Storage: This TrueDepth/ARKit information is processed entirely locally and on-device. The raw mathematical spatial orientation and facial expression data are never transmitted to Smile ID servers, nor are they shared with any third parties.

Retention & Deletion: Because this ARKit structural data remains in memory on the device temporarily during the active capture session, it is instantly destroyed as soon as the liveness check finishes. No temporary copies, caches, or backups of the ARKit depth data are ever retained or stored.

4.1.2. Dojah SDK (iOS)

Information Processed: The Dojah SDK captures facial geometry matrices and coordinate systems during its identity verification and liveness flows to analyze face depth map configurations.

Data Transmission & Storage: Similar to Smile ID, the deep hardware-level TrueDepth/ARKit data is processed locally on the user's device to establish user presence. No raw ARKit depth data or expression parameters are sent to Dojah's servers or any third-party infrastructure.

Retention & Deletion: The local ARKit mathematical data is used strictly in-memory during the selfie analysis. It is permanently deleted immediately upon completion of the verification process. Dojah does not generate or save any temporary files, local caches, or backups of this TrueDepth information.

Where personal information is transferred outside Nigeria, we apply the safeguards required by applicable data protection law.

5.1 How to Delete Your Account

You can delete your Greatiby account from within the application by opening Settings and selecting Delete, then following the instructions shown.

Deleting your account does not immediately erase records retained for the purposes explained below.

5.2 Retention After Account Deletion

Greatiby retains relevant account information, transaction records, and compliance records for up to seven years after account deletion, where necessary to:

• Comply with applicable legal and regulatory requirements.
• Maintain relevant KYC and AML records.
• Investigate fraud and resolve disputes.
• Enforce our agreements.

Retained information remains subject to the protections described in this policy. Once its applicable retention period expires and it is no longer needed for a lawful purpose, it is deleted or irreversibly anonymised.

5.3 Facial Images and TrueDepth Information

Greatiby’s seven-year retention period does not cover the selfie or TrueDepth images captured during Tier 2 verification, because Greatiby does not retain those images.

Any verification information retained by Smile ID or Dojah follows the applicable provider’s retention and deletion arrangements described in Section 4.1.

Account deletion through Greatiby and deletion of information held by a verification provider are separate processes. Provider-held records may remain subject to applicable retention requirements.

You may contact info@greatiby.com with a request concerning your verification information. We will assess the request and coordinate with Smile ID or Dojah, as applicable, subject to any lawful retention obligations.

5.4 Apple Face ID Data

Deleting your Greatiby account does not delete the Face ID data enrolled on your Apple device. You can delete that enrolled data by resetting Face ID in your device settings.

Subject to applicable law, you may:

• Request access to your personal information.
• Request correction of inaccurate or incomplete information.
• Request deletion of your information.
• Withdraw consent where processing relies on consent.
• Object to or request restriction of certain processing.
• Request a portable copy of your information where applicable.
• Raise a privacy complaint with us or the Nigeria Data Protection Commission.

Withdrawing consent does not affect processing lawfully carried out before withdrawal.

You may revoke camera permission or disable Face ID access through your device settings. Revoking permission does not automatically delete information previously collected.

We may need to verify your identity before acting on a request to protect your information against unauthorised access or deletion.

We may use cookies and similar technologies to:

• Support website functionality.
• Understand how our services are used.
• Improve user experience.
• Personalise content and advertising where applicable and permitted.

Where required, we obtain consent before using non-essential cookies or similar technologies.

Facial verification information, TrueDepth information, and Apple Face ID data are not used by Greatiby for these advertising or tracking purposes.

You can manage cookies through available website controls and your browser settings. Disabling some cookies may affect website functionality.

We may update this Privacy Policy to reflect changes in our services, verification partners, processing practices, or applicable requirements.

Updates will be published with a revised “Last updated” date. Where required, we will notify you of material changes and obtain consent before introducing processing that requires it.

For questions about this policy, privacy concerns, or requests concerning your personal information, contact:

Greatiby Limited

Email: info@greatiby.com

Website: www.greatiby.com