Privacy Policy

1. Introduction

Welcome to Sogo, a digital platform and product entirely owned, developed, and operated by FraNKAPPWeb Technologies Ltd. In this Privacy Policy, FraNKAPPWeb Technologies Ltd and the Sogo platform are collectively referred to as "Sogo", "we", "us", or "our". We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our digital platform and services.

2. Information We Collect

Personal & Business Information

Name, email address, and phone number
Government-issued identification numbers and documents (including Bank Verification Number (BVN) and National Identification Number (NIN))
Selfie photographs and video recordings for live facial verification
Bank account details and payout preferences
Residential and business physical addresses
Corporate verification data for business entities (including Corporate Affairs Commission (CAC) registration documents, corporate AML/CFT policy documents, and personal details of company Directors and Ultimate Beneficial Owners (UBOs))

Transaction Information

Gift card transaction details
Cryptocurrency transaction records
Bill payment history
Wallet balance and transaction logs

Technical Information

IP address and device information
Browser type and version
Operating system
Access times and referring website addresses
Mobile device identifiers

3. How We Use Your Information

We use the collected information to:

Provide, operate, and maintain our digital platform and services
Process transactions, calculate payouts, and send confirmations
Verify your identity and corporate status, complying with governmental KYC and KYB requirements
Administer, manage, and calculate commissions and referral bonuses for our Agent, Rewards, and Ambassador Programmes
Prevent financial crime, fraud, and enhance overall platform security (including utilizing automated screening tools to detect self-referrals, B2B/B2C identity overlaps, or attempts to manipulate our promotional and commission structures)
Comply with statutory legal, audit, tax, and regulatory compliance obligations (including AML/CFT laws)
Send transactional alerts, marketing materials, and important service updates
Analyze platform performance, improve user experience, and provide customer support

4. Information Sharing and Disclosure

We may share your information with:

Service Providers

Third-party vendors who assist us in operating our platform, including payment processors, identity verification services, and cloud hosting providers.

Legal Requirements

Law enforcement, regulatory authorities, or courts when required by law or to protect our rights and comply with legal processes.

Business Transfers

In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business.

5. Data Security

We implement industry-standard security measures to protect your information:

SSL/TLS encryption for data transmission
Encrypted storage of sensitive data
Regular security audits and monitoring
Two-factor authentication (2FA)
Secure access controls and authentication
Regular data backups

6. Data Retention

We retain your personal information for as long as necessary to:

Provide our services to you
Comply with legal obligations (minimum 5 years for financial records)
Resolve disputes and enforce our agreements
Comply with Anti-Money Laundering (AML) requirements

7. Your Rights

You have the right to:

Access your personal information
Request correction of inaccurate data
Request deletion of your data (subject to legal requirements)
Object to processing of your data
Request data portability
Withdraw consent where processing is based on consent

8. Cookies and Tracking

We use cookies and similar tracking technologies to enhance your experience, analyse usage, and improve our services. You can control cookie preferences through your browser settings.

9. Third-Party Links

Our platform may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to read their privacy policies.

10. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children.

11. International Data Transfers

Your information may be transferred to and processed in countries other than Nigeria. We ensure appropriate safeguards are in place to protect your data in accordance with this Privacy Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

Email: [email protected]