Privacy Policy

Last updated: March 2026

This data privacy, protection and cookie policy ("Privacy Policy") describes your privacy rights regarding BAYAFRIQ LTD ("Klustar", "we", "us" or "our") collection, use, storage, sharing and protection of your personal information. It applies to our website and all related sites, applications, services and tools regardless of how you access or use them.

To use our website or any of our products or services, your consent is required for the use of your data as described in this Privacy Policy.

About Us

Klustar is an online payment aggregator which facilitates online payment among individuals or companies willing to make or receive payments as the case may be (the "Service"), with the simple idea of making the flow of money and value into, within and from Africa seamless, efficient and cheap.

We are an independent contractor for all purposes, providing this website and our services on an independent service provider basis. We do not have control or assume the liability or legality for the products or services that are paid for with our service. We do not guarantee any user's identity and cannot ensure that a buyer or seller will complete a transaction.

Scope and Consent

By signing up for the use of any of our services or accessing any of our platform, its content, features, technologies, functions, you hereby consent to this Privacy Policy. You reserve the right to exercise your data protection rights as listed under the Nigeria Data Protect Act. This Privacy Policy governs the use of Klustar's Services by registered and non-registered users, unless otherwise agreed through written contract.

Collection of Personal Information

We collect Personally Identifiable Information (PII), otherwise known as Personal Information or Personal Data. They include Name, email address, phone number, contact address, limited financial information, location data, device data, etc.

How Is Your Personal Data Collected

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your personal data by filling in forms/questionnaire or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide, or we collect when you:

  • Subscribe for our products or services
  • Receive, use or enjoy our service (directly or indirectly)
  • Use your computer, mobile phone or other electronic access device on our platforms
  • Create an account on our platforms
  • Subscribe to our service, products or publications
  • Request or accept marketing or promotions to be sent to you
  • Enter a competition, promotion or survey
  • Give us feedback or contact us

Automated technologies or interactions.

As you interact with our platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources, including analytics providers, advertising networks, data brokers, open data sources, and search information providers.

How We Use Personal Information

We use the Personal Data we collect to:

  • Provide you with the required services in addition to related products and services of interest
  • Respond to your questions or requests
  • Improve features and website content, and analyse data to develop products and services
  • Address inappropriate use of our website
  • Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools
  • Send you marketing content, newsletters and service updates curated by Klustar (only with your explicit consent)
  • Verify your identity and the information you provide in line with Klustar's statutory obligations
  • Maintain up-to-date records
  • Resolve disputes that may arise, including investigations by law enforcement or regulatory bodies

Protection and Storage of Personal Information

We store and process your personal information on our computers in our premises, and anywhere else where our facilities are located. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration.

Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We have also taken additional measures by ensuring our system complies with industry information security standards.

Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information or purchased our goods or services and have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by contacting us. Where you opt out of receiving marketing messages, this will not apply to personal data provided as a result of a product purchase or service provision.

Sharing of Personal Data

We may disclose or share your Personal Information with third parties which include our affiliates, employees, officers, service providers, agents, suppliers, subcontractors as may be reasonably necessary for the purposes set out in this policy.

Klustar only shares personal information with external third parties in the following limited circumstances:

  • We have your consent
  • We share with third parties directly authorized by you to receive Personal Information
  • We provide such information to subsidiaries or affiliated companies for processing on our behalf
  • We have a good faith belief that access or disclosure is reasonably necessary to satisfy applicable law, enforce Terms of Service, detect fraud, or protect against imminent harm
  • In the event of a merger, acquisition, or sale of assets (with prior notice)

Retention of Data

We will retain your information for as long as your account is active or as needed to provide our services to you, comply with our legal and statutory obligations or verify your information with a financial institution.

Even after closing your Klustar account, we will retain certain Personal Information and transaction data to comply with legal obligations. The length of storage shall be determined by the contract terms, statutory requirements, express deletion requests (where no investigation is pending), or other lawful bases for retention.

Transfer of Data

Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction. Whenever we transfer your Personal Data internationally, we will ensure it is handled securely in line with applicable data protection laws and standard contractual clauses.

Your Rights

Individuals who have Personal Information held by Klustar are entitled to:

  • Request a copy of your Personal Data held by us
  • Request correction of inaccurate or incomplete Personal Data
  • Request erasure of your Personal Data
  • Object to the processing of your Personal Data
  • Request restriction of processing
  • Exercise your right to data portability
  • Object to automated decision-making without human intervention
  • Be informed regarding the use of your personal information
  • Request that we stop processing your personal data

In the unlikely event of an infringement on any of your rights, you are at liberty to lodge a complaint to the Nigeria Data Protection Commission (NDPC) or any other regulatory agency for redress.

Cookies

We use cookies to identify you as a User and make your user experience easier, customise our services, content and advertising; help ensure that your account security is not compromised, mitigate risk and prevent fraud; and to promote trust and safety on our website.

Our cookies never store personal or sensitive information; they simply hold a unique random reference to you so that once you visit the site we can recognize who you are and provide certain content to you. If your browser or browser add-on permits, you have the choice to disable cookies on our website, however this may impact your experience.

Children's Privacy

Our services do not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us at support@klustar.io.

Remedies

Where we notice a personal data breach or where you report any personal data breach to us, we will as soon as possible investigate same and notify you of the security or correctional measures to be taken, including reporting to relevant government authorities.

Changes to Our Privacy Policy

Subject to applicable law, we may change, amend or review this Privacy Policy at any time to reflect new services or changes in our Policy. All changes made will be posted on this page and we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Policy.

Contact Us

If you have any questions, comments, or concerns with respect to your Personal Information or this Privacy Policy, you may contact us by:

  • Reaching out to the customer service support available on the website
  • Sending an email to support@klustar.io