1. Who We Are
Halal Vault is an interest-free digital asset-backed lending platform operated by Halal Vault Holdings ("Halal Vault", "we", "us", "our"). We are the data controller for personal information collected through our website at thehalalvault.com and any associated services.
This Privacy Policy explains how we collect, use, store, share, and protect your personal data, and describes your rights under applicable data protection law — including the Nigeria Data Protection Act (NDPA) 2023 and the UK General Data Protection Regulation (UK GDPR) as applicable to your jurisdiction.
2. Data We Collect
2.1 Information You Provide Directly
- Waitlist registration: Name, email address, country of residence, digital asset holdings range, preferred exchange, and any additional information submitted via the waitlist form.
- Account registration (at launch): Full legal name, date of birth, nationality, residential address, email address, and phone number.
- KYC/AML verification: Government-issued identity document (e.g. national ID, passport, or driver's licence), proof of address, and digital asset source declaration. This data is processed by our regulated verification provider.
- Loan applications: Collateral details, requested loan amount, and repayment preferences.
- Communications: Any information you provide when you contact us by email, form, or other channel.
2.2 Information Collected Automatically
- IP address, browser type, device type, operating system, and referring URL.
- Pages visited, time spent, and click interactions on our website.
- Cookies and similar tracking technologies (see Section 9).
2.3 Information from Third Parties
- Identity verification results from our KYC/AML provider.
- Digital asset wallet and exchange data where you connect accounts or authorise data sharing.
- Publicly available information used for AML screening and sanctions checks.
3. How We Use Your Data
We use your personal data for the following purposes:
- Platform services: To process loan applications, manage collateral, disburse funds, and administer repayments under the Qard Hasan and Rahn contracts.
- Identity verification: To conduct KYC and AML checks as required by applicable financial services regulations in Nigeria and the UK.
- Compliance: To meet legal obligations under Nigerian and UK financial services law, including sanctions screening and fraud prevention.
- Waitlist & communications: To manage your waitlist registration, send platform updates, and communicate with you about your account or enquiries.
- Platform improvement: To analyse usage patterns, identify issues, and improve the platform experience.
- Security: To detect, investigate, and prevent fraudulent transactions and other illegal activities.
- Legal proceedings: To establish, exercise, or defend legal claims if necessary.
We do not sell your personal data to third parties. We do not use your data for advertising profiling or pass it to advertisers.
4. Legal Basis for Processing
Where UK GDPR or NDPA 2023 applies, we process your personal data on the following lawful bases:
- Contract performance: Processing necessary to provide the lending services you request and fulfil our obligations under your loan agreement.
- Legal obligation: Processing required to comply with KYC/AML regulations, financial reporting requirements, and other applicable law.
- Legitimate interests: Processing for fraud prevention, platform security, and service improvement — where these interests are not overridden by your rights.
- Consent: Where we rely on consent (e.g. for optional communications), you may withdraw it at any time by contacting us at privacy@thehalalvault.com.
5. Data Sharing & Third Parties
We share your personal data only where necessary and with appropriate safeguards in place:
- KYC/AML providers: Regulated identity verification services that process your identity documents on our behalf. These providers are bound by confidentiality and data processing agreements.
- Custody partners: Binance and ByBit receive collateral-related data necessary to manage digital asset custody under the Rahn contract. No personal data beyond what is required for custody operations is shared.
- Banking partners: Jaiz Bank and Taj Bank (Nigeria), Al Rayan Bank (UK) — for loan disbursement and repayment processing.
- Cloud infrastructure: Hosting and data storage providers operating under data processing agreements compliant with applicable law.
- Legal and regulatory authorities: Where required by law, court order, or regulatory mandate in Nigeria, the UK, or other applicable jurisdiction.
- Professional advisors: Legal, financial, and Shariah advisors engaged under professional confidentiality obligations.
We do not share your data with any party not listed above without your explicit consent, except where required by law.
6. International Data Transfers
Halal Vault operates across Nigeria and the United Kingdom. Your data may be transferred between these jurisdictions and to third-party service providers operating internationally. Where data is transferred outside the UK, we ensure appropriate safeguards are in place — including standard contractual clauses approved by the UK Information Commissioner's Office (ICO) or equivalent mechanisms under applicable law.
Where data is processed in Nigeria, we comply with the Nigeria Data Protection Act 2023 and regulations issued by the Nigeria Data Protection Commission (NDPC).
7. Data Retention
We retain your personal data only for as long as necessary for the purposes set out in this policy, or as required by law:
- KYC/AML records: Retained for a minimum of 5 years from the end of the customer relationship, in accordance with anti-money laundering regulations in Nigeria and the UK.
- Loan and transaction records: Retained for 7 years from the date of the last transaction, in accordance with financial record-keeping requirements.
- Waitlist data: Retained until you request removal or 24 months after the relevant platform launch, whichever comes first.
- Communication records: Retained for 3 years from the date of last contact, unless a longer period is required by law.
- Website analytics: Aggregated and anonymised data may be retained indefinitely. Individual session data is retained for no longer than 13 months.
When data is no longer required, it is securely deleted or anonymised in accordance with our data destruction procedures.
8. Your Rights
Depending on your jurisdiction, you have the following rights regarding your personal data:
- Right of access: Request a copy of the personal data we hold about you.
- Right to rectification: Request correction of inaccurate or incomplete data.
- Right to erasure: Request deletion of your data where it is no longer necessary for the purpose it was collected, subject to legal retention obligations.
- Right to restrict processing: Request that we limit how we use your data in certain circumstances.
- Right to data portability: Receive your data in a structured, machine-readable format where technically feasible.
- Right to object: Object to processing based on legitimate interests, including profiling.
- Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at privacy@thehalalvault.com. We will respond within 30 days. Some rights are subject to legal limitations — for example, we cannot erase data we are legally required to retain for AML purposes.
UK residents may also lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk. Nigerian residents may lodge a complaint with the Nigeria Data Protection Commission (NDPC) at ndpc.gov.ng.
9. Cookies & Tracking
Halal Vault uses cookies and similar technologies to operate and improve our website. The categories of cookies we use are:
- Strictly necessary: Required for core website functionality such as session management. These cannot be disabled.
- Analytics: Used to understand how visitors use the site — pages viewed, time spent, traffic sources. Data is aggregated and anonymised where possible.
- Functional: Used to remember your preferences and improve your experience.
We do not use advertising or tracking cookies. You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the website.
10. Security
We implement technical and organisational security measures appropriate to the risk of processing personal data, including:
- Encryption of data in transit (TLS) and at rest.
- Access controls limiting data access to authorised personnel only.
- Segregation of collateral data from operational platform data.
- Regular security reviews and vulnerability assessments.
- Incident response procedures for data breaches, including notification obligations under applicable law.
No method of transmission over the internet or electronic storage is 100% secure. We take all reasonable precautions but cannot guarantee absolute security. If you believe your data has been compromised, contact us immediately at privacy@thehalalvault.com.
11. Children
Halal Vault's services are not directed at or intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that personal data has been collected from a person under 18 without verifiable parental consent, we will delete it promptly. If you believe we have inadvertently collected such data, contact us at privacy@thehalalvault.com.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or regulatory requirements. When we make material changes, we will notify registered users by email and update the "Last Updated" date at the top of this policy. Continued use of our services after the effective date of any changes constitutes acceptance of the updated policy.
We encourage you to review this policy periodically. The current version will always be available at thehalalvault.com/privacy.
13. Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or your personal data, contact our data team:
- Email: privacy@thehalalvault.com
- General enquiries: hello@thehalalvault.com
- Entity: Halal Vault Holdings
We aim to respond to all privacy requests within 30 days.