Privacy Policy
v1.2 draft · 4 October 2026 · amended following legal review of 3 October; awaiting counsel's sign-offWhat we collect
Account details you give us: email address and display name. Content you create: watchlists, saved chart layouts, alerts and Community posts. Technical data: IP address, browser type and pages viewed, used to keep the service running and secure. If you choose to complete identity verification (KYC): your legal name, date of birth, address, phone, occupation, source of funds, PEP status, BVN, NIN, settlement bank account, a photo of your government ID and a short selfie video.
Purpose and lawful basis
Each category is processed for a stated purpose under a lawful basis recognised by the Nigeria Data Protection Act. Account details — to operate your account (performance of a contract). Content you create — to provide the features you use (performance of a contract). Technical data — security and service integrity (legitimate interests). Verification (KYC) data — identity verification and anti-money-laundering compliance in preparation for regulated trading (legal obligation and, while verification remains voluntary, your consent). Recipients are limited to the processors named below and to authorities where the law requires disclosure.
What we do not collect
We do not collect information about your investment objectives, risk appetite, investment holdings or trading history for the purpose of personalising our analytical outputs. Information collected for KYC, AML or regulatory purposes is used only for those purposes and is not used to personalise the analytical outputs. We do not store brokerage credentials, and we do not connect to any brokerage account of yours.
Identity verification (KYC)
Verification is optional while Akomalu is analysis-only, and becomes required before your first order once trading launches. Your BVN, NIN and bank account number are encrypted before they are stored, are never visible to the analysis features, and are accessed by staff only for verification and regulatory compliance. How long verification records are kept is set out under How long below.
Identity verification images and processors
If you choose to verify, we ask for a photo of your government ID and a short selfie video. These are sent to Smile Identity Inc., our verification provider, which checks the document and matches your face to it and to the BVN/NIN records, and returns a result to us. Smile Identity processes the images in accordance with its applicable privacy terms and our contractual arrangements with it. We do not use the images for anything else. Our other processors are Supabase (database and login, EU), Vercel (hosting), Resend (transactional email) and Termii (SMS to verified members).
Akomalu Ltd is the data controller for the personal data described in this policy. Smile Identity, Supabase, Vercel, Resend and Termii are our data processors: each processes personal data only on our instructions and under contract with us.
Why we hold it
To provide the service, to keep your settings between sessions, to secure accounts, and to understand which features are used. We do not sell personal data, and we do not use it to build advertising profiles.
Who sees it
The processors named above handle data on our behalf under contract. Community posts are public by design — your display name and post content are visible to anyone using the site. Your watchlists, alerts and layouts are private to your account.
Where it lives
Akomalu Ltd is in Nigeria, and some of our processors store or process personal data outside Nigeria. We transfer personal data outside Nigeria only as the Nigeria Data Protection Act permits: where the receiving country is recognised as giving adequate protection, under appropriate safeguards such as the data-processing terms in our contracts with these providers, or on another lawful basis the Act provides. Each provider is bound to protect the data and to use it only to provide its service to us.
How long
We keep personal data only for as long as we need it. The principal categories:
Account details and content you create (profile, watchlists, alerts, chart layouts, Community posts): while your account is open; deleted when you delete your account.
Practice-lab records (practice trades, journal notes, and the record of the fee breakdown and big-move note you saw): while your account is open; deleted when you start over in the practice lab or delete your account.
Conversations with Help while you are signed in: deleted when you delete your account.
Account-security records (such as password changes): deleted when you delete your account.
Verification (KYC) records. Where we are required by applicable securities, anti-money-laundering, tax or other legal or regulatory requirements to retain verification or regulatory records, those records will not be deleted when your account is closed. They will be securely retained for the applicable statutory or regulatory retention period and thereafter securely deleted. Where no such retention obligation applies, verification records will be deleted when your account is deleted, subject to any other lawful retention requirement.
Records of formal complaints are retained for five years from the date the complaint is received, subject to any longer period required where necessary for regulatory compliance, dispute resolution or the establishment, exercise or defence of legal claims.
You can ask us to delete your account and its content at any time, subject to the records above that we must keep.
Your rights
Under the Nigeria Data Protection Act you may request access to the personal data we hold about you, ask for it to be corrected or deleted, and object to certain processing. Write to hello@akomalu.com and we will respond.
Cookies
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Contact
Data protection requests and general enquiries: hello@akomalu.com. Akomalu Ltd, Nigeria.