This policy explains what information the Cool Data mobile app ("Cool Data," "we," "us") collects, why we collect it, who we share it with, and the choices you have. It applies to the Cool Data Android and iOS apps and to cooldata.me.
Cool Data is a bills-payment and digital-wallet app: you fund a wallet and use it to buy airtime, data, cable TV subscriptions, electricity tokens, exam result-checker pins, and similar services, and optionally earn commissions as a referral or agent.
1. Information We Collect
Account information
When you register, we collect your name, email address, phone number, and a password (stored as a salted hash, never in plain text).
Identity verification (KYC)
To comply with Nigerian financial-services regulations and to unlock higher wallet/transaction limits, we may ask for your Bank Verification Number (BVN) and/or National Identification Number (NIN). These are submitted to a licensed identity-verification provider to confirm your identity; we do not use them for any purpose beyond verification and fraud prevention.
Financial and transaction information
We keep a record of your wallet balance, funding history, and every purchase you make through the app (service type, amount, date, and status), so you can view your own transaction history and so we can investigate a failed or disputed transaction if you contact support.
We never see or store your full card number, CVV, or bank login credentials — those are entered directly into our payment processors' own secure interfaces (see Section 3), not into the Cool Data app.
Contacts (only if you use it)
If you tap the "pick from contacts" option when buying airtime or data for someone else, the app opens your phone's own contact picker and reads back only the single contact you select, to pre-fill their phone number. We do not read, upload, sync, or store your address book in bulk, and this only happens if you choose to use that feature.
Live selfie photo (identity verification)
As part of the highest identity-verification tier, we may ask you to take a short live selfie (blinking or turning your head on request) using your device's camera. This confirms a real person is present, not a static photo or a recorded video. The captured image is uploaded and stored securely on our servers for as long as your account is active, used only for identity verification and fraud prevention, and is not shared with anyone except as described in Section 3. It's permanently deleted if your account is deleted (Section 5).
Biometric unlock
This is separate from the selfie above. If you enable fingerprint/Face ID unlock to open the app, authentication happens entirely on your device through your phone's own operating system. Your fingerprint or face data never leaves your device and is never sent to us or stored on our servers — we only receive a yes/no result from the OS.
Device and push-notification data
To send you transaction alerts and wallet-credit notifications, we store a device push token (via Firebase Cloud Messaging) linked to your account. We also generate a device identifier (Android's own device ID, or Apple's equivalent) specifically to detect the same physical device being used to create multiple accounts for referral-bonus abuse — this is one signal among several we use for fraud prevention, and isn't used to track you across other apps or for advertising. We also process standard technical data such as your device type, app version, and IP address for security, fraud prevention, and troubleshooting.
2. How We Use Your Information
- To create and secure your account, and verify your identity where required by law
- To process wallet funding and purchases you initiate, and keep an accurate transaction history
- To send you transactional notifications (funding received, purchase successful/failed, security alerts)
- To detect and prevent fraud, abuse, and unauthorized account access
- To respond to support requests
- To meet our legal and regulatory obligations as a payments-adjacent service in Nigeria
We do not sell your personal information to anyone, and we do not use your data for third-party advertising.
3. Who We Share Information With
We share only what's necessary, and only with providers who need it to do the specific job below:
| Provider | Purpose |
|---|---|
| Monnify, Paystack, Palmpay, PayVessel, HitelPay | Processing wallet funding (card, bank transfer, virtual account) and payouts. Card and bank details are entered directly with these providers, not with us. |
| Google Firebase | Push notifications (Cloud Messaging) and app configuration (Remote Config) |
| ZeptoMail | Delivering transactional emails (e.g. OTP codes, account alerts) |
| Airtime/data/cable/electricity/exam-pin network providers | Fulfilling the specific service you purchase |
We may also disclose information where required by law, court order, or a valid request from a Nigerian regulatory authority.
4. Data Security
- All data in transit between the app and our servers is encrypted (HTTPS/TLS)
- Your session token and transaction PIN are stored using your device's secure hardware-backed storage (Android Keystore / iOS Keychain), not in plain app storage
- Passwords are stored as salted hashes, never in a form that can be reversed
No method of transmission or storage is 100% secure, but we take reasonable, industry-standard steps to protect your information.
5. Data Retention
We keep your account information for as long as your account is active. When an account deletion request is approved (Section 6), we immediately remove your name, email, BVN/NIN, live selfie photo, and saved beneficiaries. Your phone number and transaction/financial records are retained for the period required by applicable Nigerian financial-services regulations, which may extend beyond account closure — this is a legal obligation on our part, not a choice, and is common to all licensed payment-adjacent services.
6. Your Rights and Choices
You can:
- View your transaction history at any time in the app
- Update your profile information from the Profile tab
- Request deletion of your account from Profile → Delete My Account in the app, or without installing the app at cooldata.me/account-deletion. Because we're required to retain certain financial records, deletion requests are reviewed by our team rather than actioned instantly — you'll receive confirmation once it's processed
- Contact us (below) with any question about what data we hold about you, or to request a correction
7. Children's Privacy
Cool Data is a financial services app and is not directed at, or intended for use by, anyone under the age of 18. We do not knowingly collect information from children.
8. Changes to This Policy
We may update this policy from time to time. If we make material changes, we'll update the effective date above and, where appropriate, notify you in the app.
9. Contact Us
Questions about this policy or your data:
- Email: support@cooldata.me
- WhatsApp: +234 903 041 3368
Cool Data and General Solution Ltd