01

Introduction

13Escrow ("we," "us," "our," or the "Company") is a secure escrow platform that facilitates safe transactions between buyers and sellers by holding funds in trust until agreed-upon conditions are met. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile application, website at https://13escrow.com/ (the "Website"), and related services (collectively, the "Platform").

We are committed to protecting your privacy and handling your personal information in an open and transparent manner, in compliance with the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation, and other applicable data protection laws. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

If you do not agree with the terms of this Privacy Policy, please do not access or use the Platform. For questions, contact us at support@13escrow.com or privacy@13escrow.com.

02

Scope of This Policy

This Policy applies to all personal information collected through the 13Escrow Platform, including our mobile application (Android and iOS), Website, APIs, customer support channels, and any other services that link to this Policy.

• It applies to all users: buyers, sellers, visitors, and anyone who interacts with the Platform.
• It does not apply to third-party websites, services, or applications that you may access through links on our Platform. We encourage you to review their privacy policies.
• It covers information collected both online and offline, where such information is linked to your use of 13Escrow.
• This Policy is to be read in conjunction with our Terms of Service and Escrow Agreement, which govern your use of escrow services.

03

Personal Information We May Collect

We collect personal information that you provide directly, information collected automatically, and information from third parties, as described below.

3.1 Account Information

When you create an account, we collect your full name, email address, phone number, username, password (encrypted), profile photo, and account preferences. This is required to establish and secure your 13Escrow account.

3.2 Transaction Information

Details about escrow transactions you create or participate in, including transaction titles, descriptions, amounts, currency, conditions, delivery status, dispute records, ratings, and communication between transaction parties.

3.3 Payment Information

Bank account details, mobile money accounts, card tokens (we do not store full card numbers), transaction references, billing address, and payment history. Payment data is processed through PCI-DSS compliant providers.

3.4 Identity Verification (KYC)

As an escrow platform, we must verify identity to prevent fraud and comply with AML regulations. We collect government-issued ID (NIN, BVN, passport, driver’s license), selfie verification, proof of address, date of birth, and in some cases, video verification and business registration documents.

3.5 Communications

Content of messages you send via in-app chat, emails to support@13escrow.com, feedback forms, dispute submissions, survey responses, and call recordings (with notice) for quality assurance.

3.6 Device and Technical Information

IP address, device type, model, operating system, app version, browser type, unique device identifiers (Android ID, IDFA), crash logs, performance data, and app usage analytics. We use this to secure the platform and improve performance.

3.7 Location Information

Approximate location derived from IP address, and precise location only if you grant permission (for fraud detection and to comply with location-based regulations). You can disable precise location in device settings, but some fraud-prevention features may be limited.

3.8 Voluntarily Provided Information

Any other information you choose to provide, such as social media handles, marketing preferences, referral codes, and information submitted during promotions or beta programs.

04

How We Use Personal Information

We use your personal information for the following 12 purposes:

1. 01. To provide, operate, and maintain the escrow Platform, including creating transactions, holding funds, and releasing payments upon condition fulfillment.
2. 02. To verify your identity, authenticate your account, and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations.
3. 03. To process payments, settlements, refunds, and to prevent duplicate or fraudulent transactions.
4. 04. To facilitate communication between transaction parties and to provide customer support via support@13escrow.com and in-app chat.
5. 05. To enforce our Terms of Service, Escrow Agreements, and to resolve disputes between buyers and sellers.
6. 06. To detect, prevent, and investigate fraud, unauthorized access, money laundering, and other illegal activities.
7. 07. To improve, personalize, and develop new features, including analyzing usage trends and conducting research.
8. 08. To send transaction notifications, security alerts, policy updates, and, with your consent, marketing communications.
9. 09. To comply with legal obligations, court orders, and requests from regulators including the Nigeria Data Protection Commission.
10. 10. To perform accounting, auditing, and record-keeping for tax and regulatory compliance.
11. 11. To ensure platform integrity, perform system diagnostics, and secure our infrastructure against attacks.
12. 12. For any other purpose disclosed to you at the time of collection or with your explicit consent.

05

Legal Bases for Processing

Under the Nigeria Data Protection Act 2023, we process your personal information based on the following legal bases:

• ContractProcessing is necessary to perform our escrow contract with you and to provide the services you requested.
• Legal ObligationWe must process data to comply with NDPA, CBN regulations, AML/CFT laws, and tax laws.
• Legitimate InterestTo prevent fraud, secure the platform, improve services, and ensure business continuity, where such interests are not overridden by your rights.
• ConsentWhere you have given explicit consent, such as for marketing, precise location, or optional verification steps. You may withdraw consent at any time via privacy@13escrow.com.
• Vital InterestIn rare cases, to protect your vital interests or those of another person (e.g., preventing imminent fraud).
• Public InterestWhere processing is necessary for a task carried out in the public interest or in the exercise of official authority.

06

How We Share Personal Information

We do not sell your personal information. We share it only as necessary to operate 13Escrow and as described below.

6.1

Transaction Participants

We share limited necessary information (name, verification status, transaction history rating) between buyer and seller to facilitate trust in escrow. Full financial details are never shared between participants.

6.2

Payment Providers

With licensed payment processors, banks, and mobile money operators (e.g., Paystack, Flutterwave, banks) solely to process payments and payouts under strict confidentiality and data processing agreements.

6.3

Hosting and Infrastructure

With cloud hosting (AWS/GCP), CDN, error monitoring, and customer support tools that help us run the Platform. They are contractually bound to protect your data and cannot use it for their own purposes.

6.4

Verification Services

With KYC/identity verification partners for NIN, BVN, and document verification to meet regulatory requirements. Only the minimum necessary data is shared.

6.5

Professional Advisers

With lawyers, auditors, and accountants under professional confidentiality obligations, for legal compliance, tax filings, and dispute resolution.

6.6

Legal and Regulatory Disclosures

When required by law, court order, or request from Nigeria Data Protection Commission, EFCC, CBN, or other regulators, or to protect rights, property, and safety of 13Escrow, our users, or the public.

6.7

Business Transfers

If 13Escrow is involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, with notice to you and continued protection under this Policy.

6.8

With Your Direction or Consent

When you explicitly direct us to share information, such as integrating a third-party accounting tool or providing a reference to another user.

6.9

No Sale of Personal Information

13Escrow does not sell, rent, or trade personal information. We do not share personal information for cross-context behavioral advertising. Your escrow data remains private to your transactions.

07

Cookies, Analytics and Similar Technologies

We use cookies and similar technologies to provide, secure, and improve the Platform.

Essential Cookies

Required for login, security, escrow transaction flow. Cannot be disabled.

Functional Cookies

Remember preferences, language, and keep you logged in securely.

Analytics Cookies

Firebase Analytics, Mixpanel to understand usage and improve. Anonymized where possible.

You can manage cookies via browser settings. Mobile analytics can be limited via device ad settings. Disabling essential cookies may impair escrow functionality. We do not use third-party advertising cookies.

08

Data Security

We implement industry-standard technical and organizational measures to protect your data:

• Encryption: TLS 1.3 in transit, AES-256 at rest, encrypted database fields for sensitive PII.
• Access controls, least privilege, MFA for internal systems, audit logs.
• PCI-DSS compliant payment handling, tokenization of financial data.
• Regular vulnerability assessments, penetration testing, and secure SDLC.
• Employee training on NDPA 2023 and confidentiality obligations.

No method is 100% secure. You are responsible for safeguarding your password and enabling device biometrics. Notify us immediately of unauthorized access at support@13escrow.com.

09

Data Retention

We retain personal information only as long as necessary for the purposes outlined in this Policy:

• Account data: while account is active and 7 years after closure for legal/tax compliance.
• Transaction records: 7-10 years as required by CBN and AML regulations.
• KYC documents: 5 years after account closure or as mandated by regulators.
• Support communications: 3 years.
• Analytics logs: 26 months in anonymized form.

After retention periods, data is securely deleted or anonymized. Backup copies may persist for up to 90 days with encryption and access restrictions.

10

Account Deletion and Data Deletion Requests

Google Play Required

You have the right to delete your 13Escrow account and request deletion of your personal data. We have made this process simple and transparent in compliance with Google Play Data Safety and NDPA 2023.

How to Request Deletion:

Option 1: In-App

Settings → Account → Delete Account → Confirm with password and reason.

Option 2: Web Portal

Visit https://13escrow.com/delete-request or https://13escrow.com/ → Deletion Request Form.

Option 3: Email

Email support@13escrow.com or privacy@13escrow.com from your registered email with subject: "Data Deletion Request".

Verification

We verify ownership via OTP, ID check, and ensure no active escrow transactions before processing.

• Timeline: Requests processed within 30 days. You will receive confirmation via email.
• What is deleted: Profile, preferences, non-essential logs, device data. Transaction records required by law are anonymized, not fully deleted.
• Retention exceptions: Data required for legal, tax, anti-fraud, and dispute resolution (NDPA Section 24) will be retained in encrypted, access-restricted archives.
• Active escrows: Accounts with active escrow funds cannot be deleted until transactions complete or funds are lawfully returned.
• Revocation: You can cancel deletion within 7 days by contacting support@13escrow.com.

Email Deletion RequestOpen Deletion Portal

11

Your Privacy Rights

Under NDPA 2023, you have the following rights regarding your personal data:

Right to Access

Request a copy of personal data we hold about you in a structured format.

Right to Rectification

Correct inaccurate or incomplete data via profile settings or support@13escrow.com.

Right to Erasure

Request deletion as described in Section 10, subject to legal retention.

Right to Restriction

Request temporary restriction of processing while a dispute is resolved.

Right to Object

Object to processing based on legitimate interest or direct marketing.

Right to Data Portability

Receive your data in machine-readable format and transfer to another controller.

Right to Withdraw Consent

Withdraw consent at any time without affecting prior lawful processing.

Right to Lodge Complaint

Complain to Nigeria Data Protection Commission (NDPC) or contact privacy@13escrow.com.

To exercise rights, email privacy@13escrow.com or support@13escrow.com with your registered email, ID verification, and specific request. We respond within 30 days, extendable by 60 days for complex requests with notice.

12

International Data Transfers

Your information is primarily stored and processed in Nigeria. However, our cloud providers and support tools may process data in other jurisdictions. Where we transfer data outside Nigeria, we ensure adequate safeguards under NDPA Section 41: Standard Contractual Clauses, adequacy decisions by NDPC, or explicit consent. All cross-border transfers are documented and encrypted. A list of subprocessors and locations is available upon request at privacy@13escrow.com.

13

Children's Privacy

13Escrow is not intended for individuals under 18. We do not knowingly collect personal information from children. If you are a parent and believe your child has provided data, contact support@13escrow.com immediately and we will delete it. Users must be 18+ and have legal capacity to enter escrow contracts. KYC verification includes age checks.

14

Third-Party Services

Our Platform may contain links to third-party websites, payment gateways, or services. This Policy does not apply to them. We are not responsible for their privacy practices. We recommend reviewing their policies. When you leave 13Escrow via a link, data you provide to third parties is governed by their terms. We conduct due diligence on integrations that handle personal data.

15

Notifications and Communications

We send service-related communications essential to escrow functionality:

• Transactional: payment confirmations, escrow status changes, dispute updates, security alerts. Cannot be opted out of while account is active.
• Marketing (with consent): product updates, tips, promotions. You can opt out via app settings or unsubscribe link. Opt-out does not affect transactional messages.
• Push notifications: controllable in device settings. We use them for real-time escrow updates.
• We never send unsolicited requests for passwords or full financial details. Beware of phishing; always verify sender is @13escrow.com.

16

Fraud Prevention and Platform Integrity

To maintain a safe escrow environment, we use automated and manual systems to detect fraud, money laundering, account takeover, and policy violations. This includes device fingerprinting, behavioral analytics, transaction monitoring, and blocklist checks. Decisions may involve automated processing, with human review available on request. If flagged, your account may be temporarily restricted pending review. Contact support@13escrow.com for appeals.

17

Data Breaches

In the event of a personal data breach likely to result in risk to your rights, we will notify the Nigeria Data Protection Commission within 72 hours of becoming aware, and notify affected users without undue delay where required by NDPA Section 40. Notification includes nature of breach, categories affected, likely consequences, and mitigation measures. We maintain an incident response plan and breach register.

18

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in law, technology, or our practices. Material changes will be notified via email, in-app notification, and by updating the "Last Updated" date at the top. The updated version will be effective upon posting at https://13escrow.com/privacy-policy and in the app. We encourage you to review periodically. Continued use after changes constitutes acceptance. If you do not agree, you should delete your account via the process in Section 10.

19

Applicable Law and Regulatory Compliance

This Privacy Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including:

• Nigeria Data Protection Act 2023 (NDPA) - Primary data protection law.
• Nigeria Data Protection Regulation and NDPC Guidelines.
• Central Bank of Nigeria (CBN) regulations for escrow and payment services.
• Money Laundering (Prevention and Prohibition) Act 2022 and CBN AML/CFT Regulations.
• Cybercrimes (Prohibition, Prevention, etc.) Act 2015.

We are registered with the Nigeria Data Protection Commission as a Data Controller of Major Importance. Our Data Protection Officer can be reached at privacy@13escrow.com. Disputes related to privacy will be subject to negotiation, then mediation in Lagos, Nigeria, and courts of competent jurisdiction in Nigeria. Nothing in this Policy limits your rights under NDPA.

20

Contact Us

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

Application

13Escrow

Secure Escrow Platform

Privacy Contact

privacy@13escrow.com

Data Protection Officer

Support Contact

support@13escrow.com

General & Deletion Requests

Website

https://13escrow.com/

Official Website

Privacy Policy

https://13escrow.com/privacy-policy

Official Policy URL

Deletion Page

https://13escrow.com/delete-request

Account & Data Deletion Portal

✦

Response Commitment: We acknowledge privacy requests within 48 hours and provide substantive response within 30 days as required by NDPA 2023. For urgent data breach or security issues, mark email subject as "URGENT - SECURITY".

13

13Escrow

© 2026 13Escrow. All rights reserved.