Trubills
Trubills app.trubills.com.ng
NDPR & CBN Framework Compliant

Privacy & Data Protection Policy

How Trubills Services Limited collects, encrypts, securely stores, and responsibly handles your personal and financial information.

Effective: March 2026 • Document ID: TB-NDPR-2026-V2 • View Terms of Service
1

Introduction, Scope & Legal Framework

Trubills Services Limited ("Trubills", "we", "our", or "us") is a digital financial services and multi-utility payments platform operating through our web app (app.trubills.com.ng) and mobile applications.

This Privacy Policy describes our practices regarding the collection, use, protection, storage, and disclosure of personal data collected from registered users, merchants, buyers, sellers, and visitors.

Legal Notice: This policy is issued in strict conformity with the Nigeria Data Protection Regulation (NDPR), the Nigeria Data Protection Act (NDPA), and regulatory circulars promulgated by the Central Bank of Nigeria (CBN) and the Nigerian Communications Commission (NCC).
2

Information We Collect

To deliver instant digital fulfillment, process automated payouts, and satisfy statutory Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations, we collect the following categories of information:

A. Directly Provided Personal Information

  • Contact details: Full legal name, verified email address, and Nigerian mobile telephone number.
  • KYC & Identity verification: National Identity Number (NIN), Bank Verification Number (BVN), date of birth, and identity photo/selfie where required by financial guidelines.
  • Payout details: Destination bank name, CBN bank code, and 10-digit NUBAN account number for seller withdrawals.
  • Shop details: Business name, shop bio, store state/LGA, product descriptions, prices, and product gallery images.

B. Transaction & Billing Data

  • Recipient phone numbers for VTU airtime & data top-ups.
  • Electricity meter numbers (prepaid/postpaid) and DISCO company names.
  • Smartcard / IUC numbers for DStv, GOtv, Startimes, and Showmax.
  • WAEC, NECO, JAMB exam candidate details for electronic PIN issuance.
  • Social profile handles or URLs submitted for SMM growth boosts.
  • Virtual SMS verification transaction metadata.

C. Technical & Diagnostic Telemetry

IP addresses, browser type, operating system version, device hardware identifiers, crash logs, and cryptographic nonce timestamps captured for rate-limiting, anti-replay security, and bot defense.

3

How We Use Your Data

We process your data strictly under lawful legal bases for the following explicit purposes:

Instant Fulfillment

Dispatched tokens, data credit, electricity PINs, and cable bouquets directly to target accounts.

Fraud & AML Screening

Continuous anomaly detection, velocity monitoring, and bot protection to safeguard wallet balances.

Real-time Receipts

Dispatching instantaneous in-app receipts, Web Push notifications, and email transaction confirmation slips.

Marketplace Escrow

Releasing seller payouts only after buyers receive delivered physical orders, ensuring trust.

4

Third-Party Sharing & Integrations

We strictly limit data sharing to regulated upstream service providers who require specific transaction inputs to fulfill your orders:

  • Licensed Telecom Operators: MTN Nigeria, Airtel Nigeria, Globacom (Glo), and 9mobile for airtime and data recharging.
  • Power Distribution Companies (DISCOs): IKEDC, EKEDC, AEDC, IBEDC, KEDCO, JED, KAEDCO, PHED, YEDC, BEDC, and ABA Power for electricity token generation.
  • Entertainment Providers: MultiChoice Nigeria (DStv, GOtv, Showmax) and StarTimes for television renewals.
  • Payment Gateways & Banking Partners: Regulated commercial banks and NIBSS-licensed settlement providers (e.g. Strowallet, Monnify, Paystack) for NUBAN account name resolution and wallet funding.
Trubills does not sell, trade, or monetize personal data under any circumstances. All third parties are legally bounded by non-disclosure agreements and NDPR data processing contracts.
5

Bank-Grade Security & Cryptography

Trubills implements multi-layered defensive security across client, proxy, and database tiers:

256-Bit TLS Encryption: All client-to-server HTTP transmissions are forced over HTTPS with modern TLS 1.3 cryptographic suites.
HMAC-SHA256 Signatures & Nonces: Mutation requests carry cryptographically verified HMAC signatures, nonces, and timestamp checks to permanently prevent man-in-the-middle replay attacks.
Intelligent Rate Limiting: Automated security guards defend sensitive endpoints from brute-force intrusions, credential stuffing, and volumetric attacks.
6

Data Retention & Your NDPR Rights

Under the Nigeria Data Protection Regulation, you are guaranteed specific statutory rights regarding your personal data:

  • Right to Rectification: You may update your profile data, business name, or bank account at any time in the app settings.
  • Right to Erasure ("Right to be Forgotten"): You may request the termination and cryptographic deletion of your account.
  • Financial Audit Exception: In compliance with the Money Laundering (Prevention and Prohibition) Act and CBN audit mandates, transaction records and financial ledger receipts must be retained for a mandatory statutory period of six (6) years before automated purging.
7

Marketplace, Seller Stores & Buyer Privacy

When participating in the Trubills Shop as a buyer or merchant:

  • Delivery address details provided by buyers are shared strictly with the seller and dispatch carrier solely to execute parcel delivery.
  • Order chat communications are encrypted and monitored solely for fraud mitigation, dispute resolution, and buyer escrow protection.
  • Seller payout bank details (account name, bank name, NUBAN) are encrypted and stored solely for automated payout processing upon order delivery.
8

Data Protection Officer & Inquiries

If you have questions, grievances, or wish to exercise your data rights under NDPR, please contact our dedicated Data Protection Office:

Entity: Trubills Services Limited

Data Protection Officer: Legal & Compliance Unit

Email: dpo@trubills.com.ng

Customer Support: support@trubills.com.ng

Headquarters: Lagos State, Nigeria