The terms on which Oremi is provided, and how your information is handled. Written to be read, not to be got past.
Oremi is operated by Oremi Technologies, a product of Trade Here LTD ("Oremi", "we", "us"). We are the data controller for the personal information described in this policy. Where we act only on instructions from another party, we say so.
This policy covers information we handle when you talk to Oremi in chat, use the Oremi mobile app, visit our website, or contact support. It does not cover the messaging platforms themselves. WhatsApp and Telegram each operate under their own privacy policies, and your relationship with them is separate from your relationship with us.
It also does not cover public blockchains. Those are covered separately in section 12, because they behave differently from anything we control.
Identity and contact. Your name or chosen display name, username, phone number, and email address where you provide one.
Verification information. Where a service or applicable law requires us to confirm who you are, we collect the identifiers and documents needed for that check, and the outcome of it.
Financial information. Your wallet balances, transaction amounts, dates, references, counterparties, bank account details you save for withdrawals, and the status of each instruction.
Wallet information. Your public blockchain addresses, and an encrypted form of your recovery material. We hold that material in a form we cannot read.
Content you send us. Messages you write to Oremi, photographs you upload, voice notes you record, and support conversations.
Product records. Purchases such as airtime, data, bill payments and eSIMs, and your participation in savings circles.
Technical information. Device type and operating system, app version, notification tokens, approximate region inferred from your phone number, and security logs such as sign-in attempts.
We do not collect your contacts list, your precise location, or special category information such as health, religion or political opinions.
Most of it you give us directly, by writing to Oremi or entering it in the app. Some is generated by your use of the service, such as transaction records and security logs. A limited amount comes from the providers who carry out payments and verification on our behalf, such as confirmation that a transfer settled or that a bank account name matches.
We do not sell your personal information, and we do not share it with third parties for their own advertising.
Where data protection law requires a lawful basis, we rely on: performance of a contract, for anything necessary to give you the service you asked for; legal obligation, for identity checks, financial record keeping and reporting; legitimate interests, for security, fraud prevention and service improvement, balanced against your rights; and consent, for optional things such as marketing email, microphone access and notifications, which you may withdraw at any time.
We share only what a recipient needs, and only with these categories:
Service providers act on our instructions and are not permitted to use your information for their own purposes.
Some of our providers operate outside Nigeria and South Africa. Where information is transferred abroad, we do so on terms that require an adequate standard of protection, including contractual safeguards where the destination is not recognised as providing equivalent protection.
We keep information for as long as your account is open and you are using the service. After closure, we delete or anonymise personal information except where we are required to keep it. Financial and anti-money-laundering legislation obliges regulated businesses to retain transaction records for a minimum period after a relationship ends. We retain those records for the period the applicable legislation requires and no longer, and we detach them from your profile so they are not used for anything else.
Voice recordings are transcribed and discarded. We do not retain the audio.
We apply technical and organisational measures appropriate to the sensitivity of what we hold, including encryption of data in transit and at rest, restricted internal access on a need-to-know basis, and monitoring for unusual activity. Your recovery material is held in encrypted form that we cannot read, which means we cannot restore it for you if you lose it.
No system is perfectly secure. You protect your side by keeping your PIN and recovery material private, and by telling us promptly if you believe your account has been accessed by someone else.
Subject to the law that applies to you, you may ask us to: give you a copy of the information we hold about you; correct information that is wrong; delete your account and its data; restrict or object to certain processing; provide your information in a portable form; and withdraw consent you previously gave.
You can delete your account yourself from Settings in chat, or by writing to us. See Delete your account. We verify ownership before acting on any request, and respond within the period the applicable law allows.
If you are unhappy with how we have handled your information, you may complain to us first, and then to the relevant supervisory authority in your country.
Cryptocurrency transactions are recorded on public blockchains. Those records are permanent and public by design. Neither we nor anyone else can edit or remove them. Deleting your Oremi account removes your profile from our systems but has no effect on anything already written to a blockchain.
Oremi is not intended for anyone under 18, and we do not knowingly collect information from children. If we learn that we hold information about a child, we delete it.
Service messages, such as confirming a deposit or flagging a security event, are part of the service and are not marketing. Anything promotional is optional. Every marketing email carries a one-click unsubscribe, and app notifications can be turned off in Settings or in your device settings.
We update this policy when the service or the law changes. The date at the top always reflects the current version. Where a change materially affects your rights, we tell you directly rather than relying on you to notice.
Write to [email protected] for any privacy question, including access and deletion requests.
By creating an Oremi account or using the service, you accept these terms. If you do not accept them, do not use Oremi. Where you use Oremi on behalf of a business, you confirm you are authorised to bind that business.
You must be at least 18 and legally able to enter into a contract. You must not be subject to sanctions, or resident in a jurisdiction where the service is prohibited. You may hold one personal account. We may decline or close an account where these conditions are not met.
Your account is personal to you. You are responsible for everything done through it, and for keeping your PIN, device and recovery material secure. Do not share your PIN with anyone, including anyone claiming to be from Oremi. We will never ask for it.
Tell us immediately if you suspect unauthorised access. We may suspend access while we investigate.
Oremi is a software interface. It lets you hold and move value, buy connectivity and utilities, and organise savings with others, through a conversation.
Oremi is not a bank. We do not take deposits in the banking sense, we do not lend, and balances held through Oremi are not covered by deposit insurance. Payments to and from bank accounts are executed by licensed payment providers.
Oremi does not give financial advice. Nothing in the service is a recommendation to buy, sell or hold any asset. Decisions are yours.
Your crypto wallet is self-custodial. The material that controls it is generated for you and held in a form we cannot read. This means you, and only you, can authorise movement of those assets.
We cannot recover lost keys or recovery phrases. If you lose that material and have no backup, access to those assets is lost permanently. This is a property of self-custody, not a limitation of our support.
You are responsible for the accuracy of every instruction, including amounts, account numbers, wallet addresses and networks. Confirm details before approving.
Transactions are final. Blockchain transfers cannot be reversed by anyone once confirmed. Bank transfers, once settled, can only be recalled through the receiving institution and at its discretion. Sending to a wrong address, or on the wrong network, will usually result in permanent loss.
Exchange rates quoted in chat are indicative and valid for a short window. The rate applied is the one at execution. We may set minimum and maximum limits, and may decline an instruction where we reasonably suspect fraud, error or a legal restriction.
Fees are shown before you confirm, and are deducted at the time of the transaction. Network fees on blockchain transfers are set by the network, not by us, and vary with congestion. Third parties such as banks or card issuers may apply their own charges, which we do not control.
Cryptocurrency values move sharply and can fall as well as rise. Digital assets are not legal tender in Nigeria or South Africa, are not backed by any government, and are not protected by any compensation scheme. Regulatory treatment may change with little notice, and could affect your ability to convert assets to local currency. Do not commit funds you cannot afford to lose.
These are supplied by third-party providers. We pass on your order and the details you give us. Coverage, speed and activation are determined by the provider and the network in question, and we do not guarantee them.
Because these products are delivered immediately and consumed on use, they are generally not refundable once delivered. Where an order fails or is never delivered, we refund the amount paid. Where you supply an incorrect number or device, we cannot recover the value.
A savings circle is an arrangement between its members. Oremi provides the tooling: it schedules contributions, records them, and rotates the pot according to the order the group agrees.
We are not a guarantor. If a member stops contributing, we can suspend their participation and inform the group, but we do not underwrite the shortfall or compensate other members. Join circles only with people you trust.
We are required to monitor for suspicious activity, to verify identity in defined circumstances, and to report where the law obliges us to. We may request information or documents at any time, and may restrict an account until they are provided. We may be prohibited by law from telling you why a particular action was taken.
You may close your account at any time. Withdraw your balances first: closing destroys the wallet, and anything left in it cannot be recovered.
We may suspend or close an account where we reasonably believe these terms have been breached, where required by law or a provider, or where continuing would expose you or us to unacceptable risk. Where we may lawfully do so, we tell you and give you a reasonable opportunity to withdraw your balances.
The Oremi name, logo, interface and content are ours or our licensors'. You may use the service as intended; you may not copy, reverse engineer, or create derivative works from it. Content you submit remains yours, and you grant us only the licence needed to operate the service for you.
The service is provided on an "as is" and "as available" basis. We do not warrant that it will be uninterrupted or error free. Parts of it depend on third parties, including banks, blockchain networks, connectivity providers and the messaging platforms, and those may fail or change without notice.
Nothing in these terms excludes liability that cannot lawfully be excluded, including for fraud, or for death or personal injury caused by negligence.
Subject to that, we are not liable for indirect or consequential loss, loss of profit, loss of opportunity, or loss arising from: your own error in a transaction instruction; loss of your PIN or recovery material; movements in the value of digital assets; the acts, omissions or failures of third-party providers; or events beyond our reasonable control. Our total liability in connection with the service is limited to the fees you paid us in the three months before the event giving rise to the claim.
Raise a complaint with [email protected] and we will acknowledge it and investigate. If it cannot be resolved that way, the parties will first attempt resolution in good faith before commencing proceedings. These terms are governed by the laws of the Federal Republic of Nigeria, and the courts of Nigeria have jurisdiction, without affecting any mandatory protection available to you in your country of residence.
We may change these terms as the service or the law develops, and will post the updated version here with a new date. Material changes affecting your rights will be notified to you directly. Continuing to use Oremi after a change means you accept it.
If any provision is found unenforceable, the rest continues to apply. Our not enforcing a right on one occasion does not waive it. You may not transfer your rights under these terms; we may transfer ours as part of a reorganisation or sale of the business, without reducing your rights.
Questions: [email protected].