1. Scope of Service & Eligibility

FinanceFlex operates cloud Point of Sale, inventory intelligence, invoicing, and tax accounting. To register, you must be at least 18 years of age and authorized to conduct business in Nigeria.

2. 3-Month Free Trial & Subscription Terms

New business workspaces receive 90 days unrestricted free trial. At the expiration of 90 days, continued write-access requires selecting a paid subscription tier. Payment is processed via SitanetPay / 9PSB.

3. 9PSB Banking Rails & Prohibited Transactions

Virtual bank accounts are issued in direct integration with 9 Payment Service Bank (9PSB). Accounts must not be used for money laundering, unlicensed banking, pyramid schemes, or fraud. Prohibited use results in immediate termination and regulatory reporting to EFCC, NFIU, and CBN.

4. Director Identity Verification (NIN & BVN)

Merchants must provide authentic identity credentials (Director NIN and BVN) in accordance with CBN Anti-Money Laundering regulations.

5. Data Ownership & Multi-Tenant Isolation

Your business retains 100% ownership of your sales, stock, and customer data. We implement strict multi-tenant isolation so no other business can see your trade data.

1. Data Controller & Operator

SITANET GLOBAL ORBIT LIMITED operates FinanceFlex as the primary Data Controller for business registration and Data Processor for customer transactions.

2. Categories of Information Collected

We collect Director/Proprietor KYC data (Full Name, NIN, BVN, Phone, Email, NIN Slip), Business CAC records, and 9PSB transaction payment references.

3. 9PSB (9 Payment Service Bank) Banking Rails

Dynamic virtual collection NUBANs are provisioned in direct partnership with 9 Payment Service Bank (9PSB). Transaction references and payment status webhooks are exchanged with 9PSB to reconcile inbound bank transfers.

4. Zero Biometric Storage

Raw fingerprints, facial templates, or iris biometrics are NEVER stored on platform databases.

5. Statutory Data Subject Rights (NDPA 2023)

You have the right of access, rectification, erasure, and portability of your data. You may contact our Data Protection Officer at dpo@sitanet.ng.

6. Statutory Retention

Financial ledgers and payment logs are retained for 5 to 6 years pursuant to Central Bank of Nigeria (CBN) and FIRS tax statutory requirements.

1. Statutory & Regulatory Framework

This Platform operates in strict compliance with:

• Nigeria Data Protection Act (NDPA) 2023 enacted by the Federal Republic of Nigeria.
• Nigeria Data Protection Regulation (NDPR) 2019 administered by the Nigeria Data Protection Commission (NDPC).
• National Identity Management Commission (NIMC) Act No. 23 of 2007 governing the handling and printing of National Identity Slips.
• Central Bank of Nigeria (CBN) Regulatory Framework for BVN Operations and Watchlist 2021 issued by the CBN and NIBSS.
• Cybercrimes (Prohibition, Prevention, etc.) Act 2015.

2. Legal Roles: Data Controller vs. Data Processor

For all business operations and identity verifications conducted on this platform:

• Your Business / Workspace: Acts as the Data Controller and Verification Agent who directly interacts with the customer, collects customer identity digits, and verifies consent.
• FinanceFlex: Acts as the secure technological Data Processor routing encrypted queries to licensed identity and statutory verification gateways.

3. Two-Tier Verification Policy & Liability Rules

4. Customer Consent & Purpose Limitation (Section 25 NDPA 2023)

Personal demographic data retrieved via the Platform shall:

• Only be accessed with the explicit, informed, and unambiguous consent of the data subject.
• Be processed strictly for the verified purpose of generating an official identification slip or card for the customer.
• NEVER be mined, sold, leased, or distributed to any third-party marketing or commercial network.

5. Absolute Prohibition on Biometric & Unauthorized Data Storage

The platform strictly adheres to data minimization. Raw biometric templates (fingerprints and raw iris data) are never retained on our application servers. Transient verification records are maintained solely for statutory auditing, regulatory dispute resolution, and legal compliance as required by Nigerian law.

6. Statutory Penalties & Legal Enforcement

Under Sections 48 and 49 of the Nigeria Data Protection Act 2023, unauthorized lookup, identity theft, or fraudulent dissemination of identity records constitutes a severe criminal offence punishable by regulatory fines (up to ₦10,000,000 or 2% of annual turnover) and imprisonment. By proceeding, you agree to indemnify FinanceFlex against any liability arising from your breach of customer privacy.