Data Privacy Policy

Solnex Limited ("Solnex", "we", "us", or "our") is a technology company incorporated in Nigeria (RC8983139) that operates a Telegram-based, non-custodial cryptocurrency trading platform accessible via @tradeonsolnexbot. We enable Nigerian users to buy, sell, and convert digital assets — including SOL, USDC, and USDT — against the Nigerian Naira (NGN).

In the course of providing these services, we collect and process certain personal and financial data. This Policy sets out how Solnex collects, uses, stores, shares, and protects that data in accordance with the Nigeria Data Protection Regulation 2019 (NDPR) and the Nigeria Data Protection Act 2023 (NDPA). It also specifically addresses our obligations arising from our integration with Mono Technologies Nigeria Limited ("Mono") and the use of Mono's Connect, Prove, and Look-up products.

The data controller for all personal information processed through the Solnex platform is:

This Policy applies to all users of the Solnex Telegram bot and website. It governs personal data collected directly by Solnex and data retrieved on a user's behalf through third-party integrations, specifically:

• Mono Connect — used to securely link a user's bank account for payment initiation
• Mono Prove — used to verify a user's identity against bank-held data
• Mono Look-up — used to verify bank account details and confirm account ownership before processing transactions
• Mono Direct Debit — used to initiate NGN collections from users' linked bank accounts upon confirmed buy orders
• Mono DirectPay — used to disburse NGN payouts to users' bank accounts upon confirmed sell orders

We process personal data for the following purposes, each supported by a lawful basis under the NDPA 2023:

• Transaction processing — to execute buy and sell orders including NGN debit and disbursement via Mono Direct Debit and DirectPay (Contractual necessity)
• Identity verification — to confirm that the bank account holder matches the platform user, reducing fraud and satisfying AML/CFT obligations (Legal obligation)
• Bank account validation — to verify account details before initiating payouts via Mono Look-up (Legitimate interest)
• Fraud prevention and security — to monitor for suspicious activity and protect users and the platform (Legitimate interest / Legal obligation)
• Customer support — to respond to inquiries and resolve disputes (Contractual necessity)
• Regulatory compliance — to comply with applicable Nigerian laws and regulatory directives (Legal obligation)

Solnex integrates with Mono Technologies Nigeria Limited to power its NGN payment infrastructure. The following describes how each Mono product is used and how associated data is managed:

Solnex retains personal data only for as long as is necessary to fulfil the purposes for which it was collected or as required by applicable law:

• Transaction records and associated user data: 7 years, in line with Nigerian AML/CFT regulatory requirements
• Identity verification records: 5 years from the date of last transaction
• Bank account metadata retrieved via Mono: retained only for the duration of the active mandate or until the user revokes consent, after which it is deleted from Solnex's systems within 30 days
• Customer support correspondence: 2 years from the date of last interaction

At the end of the applicable retention period, data is securely deleted or anonymised such that it can no longer be attributed to an individual.

Solnex does not sell personal data to third parties. We share data only in the following circumstances:

• Mono Technologies Nigeria Limited — as the payment infrastructure provider, Mono receives and processes data necessary to execute payment instructions as described in Section 6
• Busha Digital Limited — as our cryptocurrency liquidity and settlement partner, Busha may receive transaction data required to process and settle digital asset trades
• Regulatory and law enforcement bodies — where required by law or court order
• Professional advisers — including legal and compliance advisers, subject to appropriate confidentiality obligations

All third-party service providers with whom we share data are required to process that data in accordance with the NDPA 2023 and to implement adequate security measures.

Solnex implements technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. These include:

• Encrypted storage of all sensitive configuration data and API credentials
• Role-based access controls limiting data access to authorised personnel only
• Secure server infrastructure hosted on enterprise-grade cloud providers
• API communications secured via HTTPS/TLS
• No storage of users' bank login credentials or card data on Solnex systems

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of users, Solnex will notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach, and affected users without undue delay.

Under the NDPA 2023, you have the following rights in respect of your personal data:

• Right to be informed — to know how your data is collected and used
• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate data
• Right to erasure — to request deletion of your data, subject to legal retention obligations
• Right to restrict processing — to request that we limit how we use your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, to withdraw it at any time

To exercise any of these rights, please contact us at support@solnexbot.com. We will respond to your request within 30 days.

The Solnex Telegram bot does not use cookies. Our website (www.solnexbot.com) may use limited analytics tools, including Google Analytics, to understand aggregate usage patterns. No personally identifiable information is collected through these tools. Users may opt out of analytics tracking through their browser settings.

The Solnex platform is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that a minor has provided us with personal data, we will take immediate steps to delete such data from our records.

Solnex reserves the right to update this Policy from time to time to reflect changes in our operations, services, or applicable law. Where changes are material, we will notify users via the Solnex Telegram channel or bot notification prior to the changes taking effect. Continued use of the platform following such notice constitutes acceptance of the revised Policy.

If you have questions about this Policy or wish to exercise your data rights, please contact:

If you are not satisfied with our response, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) at www.ndpc.gov.ng.

Signed for and on behalf of Solnex Limited