UnioGate is a venture being built to allow merchants to accept both cryptocurrency and fiat payments through a single point of sale, with automatic conversion and same-day settlement.

UnioGate is presently a pre-incorporation venture. References in this Policy to “UnioGate,” “we,” “us,” or “our” refer to the founders and team currently operating this Site and building the UnioGate product, and, upon incorporation, to the resulting registered company, which will assume responsibility for this Site and the commitments in this Policy. We will update this Policy with our registered company name and registration details once incorporation is complete.

We intend to operate in line with the Nigeria Data Protection Act 2023 (“NDPA”) and the general supervision of the Nigeria Data Protection Commission (“NDPC”), as our primary regulatory framework. Because this Site is accessible globally, we also aim to align with widely recognized data protection principles reflected in other frameworks, such as the EU/UK General Data Protection Regulation, even though we do not claim formal certification under those frameworks at this stage.

2.1 Information you give us directly

Email address. When you submit our “Get Early Access” form, we collect the email address you provide. This is currently the only piece of personal information this Site asks you to submit. We store this in a waitlist database operated for us by our infrastructure provider, Supabase (see Section 6).

Correspondence. If you contact us directly — for example by email — we will collect whatever information you choose to include in that message, so that we can respond to you.

2.2 Information collected automatically

Like virtually any website, when you visit this Site our hosting and infrastructure providers may automatically log certain technical information, including your IP address, approximate location derived from that IP address, browser type and version, device type, operating system, referring web page, and the date and time of your visit. We use this information in aggregate for purposes such as keeping the Site secure, diagnosing technical problems, and understanding general traffic levels. We do not currently use this data to build individual profiles of visitors or to track you across other websites.

To be precise about the limited scope of this Site, we want to be explicit about what we do not currently collect through it:

• We do not ask for or store passwords on this Site.
• We do not collect payment card details, bank account information, or wallet private keys through this Site.
• We do not collect government identification, know-your-customer (KYC) documents, or biometric data through this Site.
• We do not process any transaction or financial activity data through this Site, because the UnioGate product has not yet launched.
• We do not currently run advertising trackers, third-party analytics scripts, or social media pixels on this Site.

Several of these will change once the UnioGate product itself launches. See Section 13.

We use the limited information described above to:

• Maintain our early-access waitlist and contact you about UnioGate's launch, beta access, and related product updates;
• Respond to questions or correspondence you send us directly;
• Detect, investigate, and prevent abuse of our waitlist form (for example, automated or fraudulent submissions);
• Understand, in aggregate, how many people are interested in UnioGate and where that interest is coming from;
• Comply with applicable law, or respond to a valid legal request, where we are required to do so.

We do not use your email address to send unrelated marketing on behalf of third parties, and we do not sell your information. See Section 6.

Where applicable law requires us to identify a legal basis for processing your information, we rely on the following:

• Consent — by voluntarily entering your email address and submitting the waitlist form, you consent to us collecting and using it for the purposes described in this Policy. You may withdraw this consent at any time (see Section 11).
• Legitimate interest — for automatically collected technical/log data, we rely on our legitimate interest in keeping this Site secure, functional, and free of abuse, balanced against your privacy interests.
• Legal obligation — where we are required to retain or disclose information to comply with applicable law.

We do not sell your personal information. We share information only in the following limited circumstances:

• Service providers (data processors). We use Supabase, a third-party database and backend infrastructure provider, to store waitlist submissions on our behalf. Supabase processes this data only as instructed by us and is not permitted to use it for its own purposes. We may in future use additional infrastructure, email-delivery, or analytics providers under similar terms; if so, this Policy will be updated.
• Legal and safety reasons. We may disclose information if required to do so by law, by a valid order from a court or regulator, or where we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business transfers. If UnioGate is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will require any such party to honor the commitments in this Policy, and will notify you of any material change in how your information is handled.

We retain waitlist email addresses for as long as is reasonably necessary to fulfill the purposes described in this Policy — principally, so that we can contact you about UnioGate's launch.

If UnioGate's launch does not proceed, or if a significant period passes without any product update (we consider 24 months without contact from us a reasonable outer bound), we will either delete waitlist data we no longer have a reasonable use for, or seek your renewed consent before continuing to hold it. You can also ask us to delete your information at any time — see Section 11.

As of the date of this Policy, this Site does not set advertising or analytics cookies, and does not use third-party tracking pixels. Our hosting and infrastructure providers may use a small number of strictly necessary technical cookies or local storage values required for the Site to function (for example, to keep a security or session token).

If we introduce analytics, advertising, or other non-essential cookies in the future, we will update this section and, where required by applicable law, present you with a cookie consent banner before any such cookies are set.

We take reasonable technical and organizational measures designed to protect your information, including: encrypting data in transit between your browser and our Site (HTTPS/TLS); relying on Supabase's infrastructure-level security controls and access restrictions for stored data; and limiting internal access to waitlist data to the founders and team members who need it to operate the waitlist.

No method of transmission or storage is 100% secure, and we cannot guarantee absolute security. If we become aware of a data breach affecting your information, we will notify you and the NDPC as required by applicable law.

Our infrastructure provider, Supabase, may process and store data on servers located outside Nigeria, depending on the cloud region configured for our project. By using this Site, you understand that your information may be processed in a country other than the one in which you reside, and that the data protection laws of that country may differ from those of your home country. Where required, we take steps intended to ensure such transfers are subject to appropriate safeguards.

Subject to applicable law — including, for users in Nigeria, the NDPA — you have the right to:

• Access — ask us to confirm whether we hold your information and provide you with a copy of it;
• Rectification — ask us to correct inaccurate information (for example, an email address you mistyped);
• Erasure / withdrawal — ask us to delete your email address from our waitlist at any time, for any reason;
• Restriction — ask us to limit how we use your information in certain circumstances;
• Objection — object to our processing of your information where we rely on legitimate interest;
• Portability — ask us to provide your information in a structured, machine-readable format;
• Complaint — lodge a complaint with the Nigeria Data Protection Commission, or with the relevant data protection authority in your country of residence.

To exercise any of these rights, contact us using the details in Section 15. Because this Site currently only holds your email address, most requests (especially deletion) can typically be completed quickly.

This Site is not directed at, and is not intended for use by, anyone under the age of 18. We do not knowingly collect information from children. If you believe a child has provided us with their email address, please contact us and we will delete it.

This Policy is intentionally scoped to this pre-launch waitlist Site. Once the UnioGate application itself launches, the scope of data we collect and process will expand substantially, and will likely include — among other things — identity verification information (such as government-issued ID, business registration documents, and KYC/KYB checks), transaction and payment data, device and wallet information necessary to process crypto and fiat payments, and information needed to comply with anti-money laundering and financial regulatory obligations in the jurisdictions in which we operate.

Before any of that data collection begins, we will publish a new, comprehensive Privacy Policy describing it in full, and you will be asked to review and accept that policy separately — joining this waitlist today does not constitute consent to the data practices of the future UnioGate product.

We may update this Policy from time to time as this Site evolves — for example, if we add analytics, change infrastructure providers, or formally incorporate. We will update the “Last updated” date at the top of this page when we do, and where a change is material, we will take reasonable steps to make it prominent (such as a notice on this Site). We encourage you to review this page periodically.

If you have questions about this Policy, or want to exercise any of the rights described in Section 11, please contact us at: