Privacy Policy — TrothFin

1. Who we are

TROTHFIN LIMITED, a company registered in Nigeria with registration number RC 9818424, is the data controller responsible for your personal information.

Registered office: No 8 Olasoju Adebayo Street, Ali Dada, Ago Palace, Lagos State, Nigeria
Email: support@trothfin.com
WhatsApp: +2349034753675

2. Information we collect

We collect the following categories of personal information, most of it directly from you during WhatsApp onboarding or from your employer when they add you to their payroll roster:

Your WhatsApp phone number, used as your account identity.
Your full name.
Your National Identification Number (NIN) and Bank Verification Number (BVN).
Your bank name and account number, for receiving payouts.
Bank statements you upload for employer verification (up to six months). We extract text from these files — including running optical character recognition (OCR) on scanned documents — to check that your employer's name appears in them.
A transaction PIN you choose, which we store only as a one-way cryptographic hash — we never see or keep the PIN itself.
Records of the withdrawal tokens issued to you and the withdrawals you make, including amounts, fees and dates.
Roster information provided by your employer, such as your monthly salary and payroll identifiers.
Attendance records your employer logs for you (the days you worked).
Leave requests you send through WhatsApp: the type (annual, casual or medical), the dates and any short note you choose to add, and your employer's decision. Please don't put medical details in the note — the type of leave is enough.
Employment-status records your employer sets, such as a resignation or termination date, which end your access to TrothFin.
Your choice to opt in or out of company announcements, and a log of which announcements were sent to you.
Messages you send us through the website contact form or WhatsApp support (name, email, company and message).

3. How we use your information

To verify your identity and confirm your employment before you can transact.
To check your uploaded bank statements against your employer's details.
To issue, validate and redeem earned-wage-access tokens.
To process payouts to your bank account.
To operate our fraud controls, including the identity gate that locks a token to the phone number it was issued to.
To reconcile withdrawals with your employer for payroll deduction on payday.
To comply with legal, regulatory, tax and anti-money-laundering obligations.
To respond to your support requests and to notify you about your account.
To let your employer run HR administration through TrothFin: attendance and leave records, payroll reconciliation, staff announcements and exit processing.

4. Legal basis for processing

We process personal information under the Nigeria Data Protection Act 2023 and the Nigeria Data Protection Regulation, relying on: performance of a contract with you; our legitimate interest in preventing fraud and operating the service securely; compliance with a legal obligation; and your consent, which you give when you complete WhatsApp onboarding and which you may withdraw at any time.

5. How we share your information

We do not sell your personal information. We share it only as needed to run the service:

Meta Platforms, Inc., which delivers the WhatsApp messages between you and TrothFin.
Our payment processor (Paystack) and the banking infrastructure used to send your payout.
Identity- and business-verification providers used to validate KYC/KYB information.
Your employer, who receives the status and amount of your withdrawals so they can deduct them from your salary.
Regulators, law enforcement or courts where we are legally required to disclose information.
Professional advisers and service providers who process data on our behalf under confidentiality obligations.

6. How long we keep your information

We keep your personal information for as long as your account is active and for as long afterwards as we are required to retain financial and transaction records under Nigerian law. When a retention period ends, we delete or irreversibly anonymise the information.

7. Your rights

Subject to Nigerian data protection law, you have the right to access the personal information we hold about you, to have it corrected, to request its deletion, to object to or restrict certain processing, and to withdraw consent. You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

8. Data deletion

To request deletion of your personal information, email support@trothfin.com from the address on your account, or send a message to our WhatsApp number +2349034753675 with the word DELETE. Tell us the phone number registered with TrothFin.

We will acknowledge your request within 7 days and complete it within 30 days. We will delete your identity, KYC and uploaded-statement data. We may need to retain a minimal record of completed transactions where the law requires us to keep financial records; we will tell you if this applies and for how long.

9. How we protect your information

Transaction PINs are stored only as salted one-way hashes. Data is transmitted over encrypted connections, access to production systems is restricted, and uploaded bank statements are processed only for verification and then handled under our retention rules.

10. Children

TrothFin is intended only for employed adults aged 18 or over. We do not knowingly collect information from anyone under 18.

11. Changes to this policy

We may update this policy from time to time. Material changes will be notified through the service or by message. The “last updated” date above shows when this version took effect.

12. Contact us

Questions about this policy or your personal information: email support@trothfin.com or write to TROTHFIN LIMITED, No 8 Olasoju Adebayo Street, Ali Dada, Ago Palace, Lagos State, Nigeria.