Privacy Policy

Etairia Global Ltd ("we", "our", or "us") operates the FinTrackmobile application and related services (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

By downloading or using the FinTrack app, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this policy, please do not use the Service.

This policy applies to:

• The FinTrack Android mobile application
• Our website at https://etairiaglobal.com
• All services, features, and functionality offered by Etairia Global Ltd

We collect information you provide directly to us, information generated through your use of the Service, and in limited cases, information from your device. We only collect data that is necessary to provide and improve the Service.

We use the information we collect only for the purposes described below. We will not use your personal data for any purpose that is incompatible with the original reason it was collected without first obtaining your consent.

• To provide the Service: Create and manage your account, process your financial entries, and generate reports.
• To improve the Service: Analyse usage patterns and performance to fix bugs and develop new features.
• To communicate with you: Send service-related notifications, security alerts, and respond to your support enquiries.
• To ensure security: Monitor for fraud, abuse, or unauthorised access and protect your account.
• To comply with legal obligations: Comply with applicable laws, regulations, and lawful governmental requests.
• To generate anonymised insights: Produce aggregated, anonymised statistics that cannot identify you individually.

We do not sell your personal data. We do not use your financial data or personal information for advertising or marketing purposes beyond communications directly related to our own Service.

Where applicable (including under the EU General Data Protection Regulation — GDPR — and the Nigerian Data Protection Act — NDPA), we process your personal data on the following legal bases:

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following limited circumstances:

We retain your personal data only for as long as is necessary for the purposes set out in this policy, and as required by applicable law.

When your data is no longer required, we securely delete or anonymise it. Where we are unable to immediately delete data for technical reasons, we will isolate it from further processing until deletion is possible.

In accordance with Google Play's Account Deletion Requirements, if you create an account in FinTrack, you have the right to request deletion of your account and associated data at any time.

You can request account deletion through either of the following methods:

• In-app: Go to Settings → Account → Delete Account within the FinTrack app.
• Online: Submit a deletion request by emailing info@etairiaglobal.com with the subject line "Account Deletion Request".
• Website: Use the account deletion form at https://etairiaglobal.com/contact.

Upon receiving a valid deletion request, we will:

• Delete your account and personally identifiable data within 30 days
• Send you a confirmation email once deletion is complete
• Retain certain data where we have a legal obligation to do so (e.g. financial records for 7 years as required by Nigerian tax law), with clear notice to you
• Delete all backup copies within 90 days

We implement industry-standard security measures to protect your personal and financial data against unauthorised access, alteration, disclosure, or destruction.

• Encryption in transit: All data transmitted between your device and our servers uses TLS 1.2+ (HTTPS).
• Encryption at rest: Sensitive data stored on our servers is encrypted using AES-256.
• Access controls: Strict role-based access controls limit who within our team can access your data.
• Authentication: Secure password hashing (bcrypt) and optional two-factor authentication.
• Regular audits: We conduct periodic security reviews and vulnerability assessments.
• Incident response: We maintain a data breach response plan and will notify affected users within 72 hours of becoming aware of a breach, as required by law.

While we take all reasonable steps to protect your data, no method of electronic storage or transmission over the internet is 100% secure. We cannot guarantee absolute security.

The FinTrack Service is intended for use by adults and business operators. The app is not directed at children under the age of 13, and we do not knowingly collect personal information from children under 13 years of age.

If we become aware that we have inadvertently collected personal data from a child under 13 without verified parental consent, we will take immediate steps to delete that information. If you believe we may have collected data from a child under 13, please contact us at info@etairiaglobal.com.

Depending on your location, you may have the following rights regarding your personal data. We will respond to all verifiable requests within 30 days.

To exercise any of these rights, contact us at info@etairiaglobal.com. We may need to verify your identity before fulfilling a request.

The FinTrack app may use third-party SDKs and services to deliver functionality. All third-party providers are vetted for compliance with applicable data protection laws. We ensure that any third-party code in our app does not sell your personal data.

Currently, we may use services in the following categories:

• Cloud Infrastructure: Secure hosting and database services for storing your data.
• Analytics: Anonymised, aggregated usage analytics to improve app performance (no personal identification).
• Crash Reporting: Automated crash logs to identify and fix app bugs quickly.
• Authentication: Secure account verification services.

Our app does not currently include third-party advertising SDKs. If this changes, we will update this policy and obtain appropriate consent.

Links within the app or our website to third-party sites are governed by their own privacy policies. We are not responsible for the content or practices of those sites.

Etairia Global Ltd is based in Nigeria. Your data is primarily stored and processed in Nigeria. In some cases, our third-party service providers may process data in other countries.

Where we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Using service providers that comply with recognised data protection frameworks (including EU-U.S. Data Privacy Framework where applicable)
• Implementing Standard Contractual Clauses (SCCs) for transfers to countries without an adequacy decision
• Ensuring equivalent levels of protection as required by the Nigerian Data Protection Act (NDPA)

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page
• Notify you via in-app notification or email at least 14 days before changes take effect
• For significant changes, request your renewed consent where required by law

We encourage you to review this policy periodically. Continued use of the Service after changes become effective constitutes acceptance of the updated policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your data, please contact us:

You may also submit a privacy request online: https://etairiaglobal.com/contact