Privacy Policy

Last Updated: January 18, 2025

Middleman Technologies Ltd (“Middleman,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal data. This Privacy Policy explains how we collect, use, store, share, and protect information when you use the Middleman mobile application, website, and related services (collectively, the “Platform”).

By using Middleman, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of This Policy

This Privacy Policy applies to:

  • All users of the Middleman Platform
  • All personal data collected directly or indirectly
  • All processing carried out by Middleman, its staff, contractors, and service providers

This Policy should be read together with our Terms and Conditions.

2. Information We Collect

We collect information necessary to operate, secure, and improve the Platform.

2.1 Information You Provide

  • Full name
  • Email address
  • Phone number
  • Date of birth
  • Government-issued ID documents (KYC)
  • Selfies and verification images
  • Payment and transaction details
  • Messages, files, and evidence submitted during disputes

2.2 Information Collected Automatically

  • Device information
  • IP address
  • Location data (approximate)
  • Log data and usage history
  • Cookies and similar technologies (where applicable)

2.3 Information from Third Parties

  • Payment service providers
  • Identity verification providers
  • Fraud prevention services
  • Compliance and sanctions screening databases

3. Why We Collect and Use Data

We process personal data to:

  • Create and manage user accounts
  • Facilitate wallets, escrow, and challenges
  • Verify identity (KYC / AML)
  • Prevent fraud, abuse, and illegal activity
  • Resolve disputes and appeals
  • Comply with legal and regulatory obligations
  • Improve Platform performance and security
  • Communicate service updates and notices
Note: We do not sell personal data.

4. Legal Basis for Processing

We process personal data based on one or more of the following:

  • Performance of a contract (providing the Platform)
  • Legal and regulatory obligations
  • Legitimate business interests (fraud prevention, security)
  • User consent (where required by law)

5. KYC, AML & Compliance Data

Identity verification data may be:

  • Collected directly from you
  • Shared with licensed KYC and compliance providers
  • Retained for legally required periods

Middleman may deny, restrict, or terminate access if KYC requirements are not met.

6. How We Share Information

We may share personal data with:

  • Payment service providers
  • Identity verification and compliance partners
  • Law enforcement or regulators (where legally required)
  • Service providers under confidentiality obligations

We do not control how third-party services process data once lawfully shared.

7. Disputes, Evidence & Communications

When disputes are raised:

  • Messages, files, and evidence may be reviewed by admins
  • Data may be retained even after dispute resolution
  • Evidence may be shared with relevant parties where necessary

Admins may rely on available data and reasonable judgment.

8. International Data Transfers

Your data may be processed or stored outside your country of residence.

By using Middleman, you consent to international data transfers, subject to reasonable safeguards.

9. Data Retention

We retain personal data:

  • As long as your account is active
  • As required by law or regulators
  • As necessary for fraud prevention, disputes, or enforcement

Middleman may retain certain data even after account closure.

10. Your Rights

Depending on your jurisdiction, you may have rights to:

  • Access your personal data
  • Request correction of inaccurate data
  • Request deletion (subject to legal limits)
  • Withdraw consent where applicable
⚠️ Important: These rights are not absolute. Requests may be refused where data retention is required by law, security, or legitimate business interests.

11. Account Deletion

If you request account deletion:

  • Certain data will be retained for compliance and legal purposes
  • Transaction and dispute records may not be deleted
  • Deletion does not remove obligations already incurred

12. Cookies & Tracking

We may use cookies or similar technologies to:

  • Maintain sessions
  • Improve performance
  • Prevent abuse

You may disable cookies, but some features may not function properly.

13. Security Measures

We implement reasonable technical and organizational safeguards, including:

  • Access controls
  • Encryption where appropriate
  • Audit logging
  • Role-based admin access

However, no system is completely secure, and Middleman cannot guarantee absolute security.

14. Staff & Admin Access

Authorized Middleman staff may access personal data strictly on a need-to-know basis for:

  • Support
  • Compliance
  • Dispute resolution
  • Security monitoring

All admin actions are logged.

15. Third-Party Links

The Platform may contain links to third-party services. Middleman is not responsible for third-party privacy practices.

16. Children’s Privacy

Middleman is not intended for individuals under 18 years. We do not knowingly collect data from minors.

17. Limitation of Liability

To the maximum extent permitted by law:

  • Middleman is not liable for unauthorized access beyond reasonable control
  • We are not responsible for third-party service failures
  • Liability related to data protection is limited as provided in our Terms

18. Changes to This Policy

We may update this Privacy Policy from time to time.

  • Material changes may be notified in-app
  • Continued use constitutes acceptance

19. Contact Information

For privacy-related inquiries:

📧 support@midman.app
🏢 Middleman Technologies Ltd
📍 Nigeria