Privacy Policy

Who we are

Passcode is operated by Passcode Technologies Limited, a company registered in Nigeria. Where this policy says “we”, it means that company. Where it says “your community”, it means the estate, office, school or other place whose administrators invited you or approved your request to join.

What we collect

Things you give us

• Your phone number. This is how you sign in. We send a one-time code to it. We do not store a password.
• Your name, and your email address if you give one. Your name is shown to your community’s administrators and, where a directory exists, to other members of the same place.
• A profile photograph, if you upload one.
• Your address within a community — a flat, a unit, a house number — and how you hold it, such as tenant or owner.
• Details of visitors you invite: their name, their phone number, and optionally who they work for, a vehicle plate and a note for security.

Things we collect because you use the product

• Gate and door events. When a card, wristband or code is presented at a reader, we record which credential it was, where, and when.
• Attendance records, at workplaces and schools that use Passcode for it — the times a credential was presented at the entrance.
• Payments and balances. What you have been charged, what you have paid, what is outstanding, and the record of each transaction.
• Things you report — incidents, faults and emergency alerts, including any photograph you attach and any location you type in.
• Messages you send through the app to your community’s administrators, and any file you attach to one.
• Basic device and technical information — device type, operating system version, app version, and IP address — used to run the service and investigate faults.

Identity and financial information

Some things are asked for only when you do something that requires them, and never before:

• Your BVN and date of birth are requested only if you choose to send money out of your Passcode balance, or to open a Passcode account number in your name. Nigerian financial regulation requires this check before a transfer can be originated. You are never asked for a BVN to hold a balance, to add money, to pay your dues, or to open a gate. Your BVN is passed to our payment provider for verification and is not stored in readable form by us.
• Identity documents, where your community requires a higher level of verification before granting you access.
• Card and bank details are never seen by Passcode. When you add money, you are handed to our payment provider’s own checkout page and enter them there.

Why we hold it

• To let you in, and to let the people you invite in.
• To show your community’s administrators who is on their register.
• To bill, collect and record dues, levies and other payments.
• To alert whoever is on duty when you raise an emergency.
• To meet legal obligations, including the identity checks required before money can be moved, and to keep financial records for as long as the law requires.
• To investigate faults, abuse and disputes.

We do not sell your information. We do not use it to build advertising profiles, and we do not share it with advertisers.

Who can see what

Passcode is used by communities, so some of what we hold is visible to people in yours. This is worth being precise about:

• Administrators of a place you belong to can see your name, your address there, your standing, what you owe that community, the visitors you have invited to it, and gate events at that place. They cannot see your wallet balance or anything about other communities you belong to.
• Security officers on duty see the passes expected at the gate and the people who present them.
• Other members may see your name and role in a directory, where your community has one.
• Your landlord, if you are a tenant, is asked to approve property you declare as leaving the premises.

One community cannot see your data at another. Your balance, your transaction history and your identity documents are yours and are not shown to administrators.

Who we share it with

• Our payment provider, for verification, collections and transfers.
• Our messaging providers, to deliver the SMS containing your sign-in code and other notifications.
• Our hosting and storage providers, who run the servers and store uploaded images.
• Law enforcement or a regulator, where we are legally required to respond.

How long we keep it

Financial records are kept for at least seven years, because Nigerian law requires it. Gate and attendance events are kept while you belong to that community and for a period afterwards, so that disputes about what happened at a barrier can be settled. Everything else is deleted when you ask us to, or when your account is closed, whichever is sooner.

Deleting your account

You can ask us to delete your account and the information attached to it at any time. See how to delete your account.

Some records survive deletion, and we would rather say so than surprise you: financial transactions and the gate events belonging to a community are retained for the periods above. Where that happens, they are detached from your profile and kept only as the community’s own record.

Your rights

Under the Nigeria Data Protection Act you may ask us for a copy of what we hold about you, ask us to correct it, ask us to delete it, or object to how we use it. Write to privacy@passcode.ng and we will respond within 30 days.

Security

Traffic between the apps and our servers is encrypted. Your sign-in token and transaction PIN are held in your phone’s secure storage, not in ordinary app data. A PIN is required before money leaves your balance. We are not able to read your PIN, and cannot tell you what it is if you forget it — you reset it with a code sent to your phone.

Children

Passcode is not intended for children to sign up for on their own. Where a school uses Passcode, a child’s attendance and pickup records are held on behalf of that school and are visible to their parent or guardian and to the school.

Changes

If we change this policy we will update the date at the top, and tell you in the app if the change is significant.

Contact

privacy@passcode.ng
Passcode Technologies Limited, Lagos, Nigeria.