Privacy Policy - MamaSave

Last Updated: June 20, 2026

1. PREAMBLE & OBJECTIVE

This Privacy Policy (“Policy”) describes how PEARL SYSTEMS LIMITED (“the Company”, “we”, “us”, or “our”), the legal owner and operator of the proprietary digital financial technology product MamaSave, collects, uses, records, structures, stores, retrieves, discloses, and protects the personal and financial information of our users, field collection agents, and visitors (“you” or “Data Subject”).

This Policy is drafted in strict compliance with the Nigeria Data Protection Act (NDPA) 2023, the Nigeria Data Protection Regulation (NDPR), and other applicable digital financial services guidelines issued by the Central Bank of Nigeria (CBN). Pearl Systems Limited acts as the official Data Controller under the law for the purposes of managing the daily micro-savings, community crowdfunding, and associated financial inclusion services deployed via our official web platform (mamasave.ng) and associated mobile applications.

2. PRINCIPLES OF DATA PROCESSING

In line with Section 24 of the NDPA 2023, the Company processes your personal data adhering strictly to the following core tenets:

Lawfulness, Fairness, and Transparency: Collected only with your explicit consent or via valid legal/contractual bases.
Purpose Limitation: Processed solely for explicit, specific, and legitimate business operations under the MamaSave platform.
Data Minimization: Limited only to the absolute necessary details required to run your savings account.
Accuracy: Maintained and kept up-to-date to ensure account integrity.
Storage Limitation: Kept only for as long as necessary to fulfill financial regulatory requirements.
Integrity and Confidentiality: Secured utilizing modern technical encryption to protect against unauthorized access, leaks, or breaches.

3. THE DATA WE COLLECT

To provide secure, micro-savings cooperative and financial ledger services, we collect the following categories of personal information through MamaSave:

Identity & Account Onboarding Data: Full Name, Date of Birth, Gender, Residential/Stall Address, Local Market Zone, Passwords, Access PINs, and Government-issued identification (NIN or Voter’s Card).
Contact Data: Valid Mobile Phone Number and Email Address.
Financial & Verification Data: Bank Verification Number (BVN), Bank Account Number, and Dedicated Virtual Account (DVA) numbers generated via our licensed partner Payment Service Providers (PSSPs) and Microfinance Banks (MFBs).
Transaction Data: Timestamps, deposit values, daily calendar grid history, missed contribution records, and transaction logs generated through our platform rails.
Technical & Device Telemetry: Device Unique Identifiers (UUID/IMEI), IP addresses, and login audit trails collected to track device-to-account ratios and mitigate multi-account or bot fraud networks.

4. THE LAWFUL BASIS FOR PROCESSING DATA

Under Section 25 of the NDPA 2023, the Company relies on the following legal grounds to process your information:

Consent: Your explicit, unambiguous approval given when creating an account or funding a savings cycle on MamaSave.
Performance of a Contract: Necessary to execute your daily savings rules, process payout withdrawals, and manage cooperative distributions.
Legal Obligation: Mandatory processing required to satisfy anti-money laundering (AML), combating the financing of terrorism (CFT), and KYC identity tracking laws binding our financial aggregators.
Legitimate Interests: Necessary to prevent system fraud, enforce device spam caps, block security threats, and protect the financial integrity of the marketplace community.

5. HOW WE USE YOUR DATA

The Company utilizes your personal records exclusively to:

Validate your identity and prevent fraudulent account creation.
Track daily contributions, compile market zone ledgers, and trigger automated 7:00 AM Agent Daily Briefing push messages/SMS alerts.
Facilitate payouts, settle webhooks from partner commercial banks, and clear financial processing queues.
Investigate security alerts, detect multi-account abuse rings via device telemetry, and enforce platform transaction limits.

6. DATA RETENTION AND STORAGE LIMITS

Your personal information is stored securely within isolated cloud database instances featuring end-to-end encryption. In accordance with Central Bank of Nigeria (CBN) anti-money laundering frameworks and financial bookkeeping laws, transactional logs and fundamental identity metadata will be securely retained by Pearl Systems Limited for a mandatory period of five (5) years following the formal closure of your MamaSave account. After this statutory period, data is completely anonymized or permanently deleted from active production servers.

7. THIRD-PARTY DATA DISCLOSURES

We do not sell, rent, or lease your personal data to third parties. We share data only with authorized external institutions necessary to complete your financial transactions:

Licensed Banking Partners & PSSPs: Core settlement banks and payment switches processing your inbound DVAs and transfer payouts.
Regulatory Authorities: The Nigeria Data Protection Commission (NDPC), the Central Bank of Nigeria (CBN), or law enforcement agencies when explicitly compelled by an official legal order.

8. YOUR LEGAL DATA SUBJECT RIGHTS

Under Part IV of the NDPA 2023, you possess the following explicit legal rights regarding your data on the platform:

Right to Information & Access: The right to request an electronic copy of all data we hold about you.
Right to Rectification: The right to update or correct inaccurate profile details via your agent or admin panel.
Right to Erasure (“Right to be Forgotten”): The right to request account deletion, subject to the statutory 5-year financial retention laws.
Right to Restrict Processing: The right to temporarily halt active data processing pending the resolution of an account dispute.
Right to Data Portability: The right to download your account ledger records in a structured, machine-readable format.
Right to Withdraw Consent: The right to revoke your processing permission at any time.

To exercise any of these rights, please contact our designated Data Protection Officer using the credentials listed in Section 11. All legitimate requests will be resolved within thirty (30) days free of charge.

9. DATA SECURITY & BREACH NOTIFICATION PROTOCOLS

We deploy military-grade technical architectures, including Secure Socket Layer (SSL/TLS) data transmission encryption, hashing protocols for user PINs, server-side firewalls, and role-based access management constraints for admins and agents.

In the highly unlikely event of a validated security compromise or third-party data leak, the Company will deploy its active Incident Response Playbook to contain the threat and will formally notify the Nigeria Data Protection Commission (NDPC) within 72 hours of discovery, in strict compliance with Section 40 of the NDPA 2023. Impacted users will be directly alerted via SMS or registered email channels immediately following containment.

10. COOKIES AND LOCAL TRACKING TELEMETRY

Our portal uses small tracking identifiers known as cookies and device tokens to sustain encrypted login sessions, authenticate active admin dashboard states, and analyze user navigation trends to improve app layout. You can disable cookies inside your web browser settings, though doing so may prevent certain automated screens from loading.

11. REVISIONS TO THIS PRIVACY POLICY

The Company reserves the right to periodically alter, amend, or update this Policy to match new NDPC administrative rules or software upgrades. Whenever amendments are committed, we will revise the “Last Updated” timestamp at the apex of this document and publish a prominent banner across the admin and customer interfaces.

12. CONTACT OUR DATA PROTECTION OFFICER (DPO)

If you have questions, grievances, or wish to submit a data rectification request, please contact our internal compliance desk:

Corporate Legal Entity: Pearl Systems Limited
Proprietary Brand Platform: MamaSave
Designated Data Protection Officer: Daniel Salathiel Ogolo
Corporate Website Address: https://mamasave.ng
Official Compliance Email Address: privacy@mamasave.ng
Registered Physical Address: 74 G.U. Ake Road (Eliozu Road,) Eliozu, Port Harcourt, Rivers State