Last Updated: April 14th, 2026
Entity: Cometstar Technologies Limited
1. Introduction
This Privacy Policy describes how Cometstar Technologies Limited (“we,” “us,” or “our”) collects, uses, and shares your personal information specifically in relation to the **ComePay Multi-Currency** application and its associated global financial services. This policy is designed to comply with the Nigeria Data Protection Act (NDPA) and international financial data standards.
2. Information We Collect
Because the ComePay Multi-Currency app involves international banking and foreign exchange, we collect more extensive information than our standard local services:
Identity Data: Full name, date of birth, and nationality.
Enhanced KYC Documents: International Passport, National ID / BVN, or Voter’s Card images and numbers.
Financial Data: Source of wealth, transaction history, and currency conversion records.
Technical Data:IP address, device type, and geolocation (required for fraud prevention in cross-border transactions).
3. How We Use Your Information
We use your data to:
Generate and manage your multi-currency virtual accounts (USD, GBP, EUR, NGN).
Facilitate currency swaps and foreign exchange transactions.
Issue and manage virtual cards.
Perform Mandatory Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) screenings.
4. Sharing with Third-Party Infrastructure Partners
To provide global financial services, we must share your data with specific licensed infrastructure providers. By using this app, you consent to your data being shared with:
Financial API Partners: Licensed providers (such as Fincra) to facilitate account generation, global pay-ins, and pay-outs.
Card Issuing Partners: Providers (such as Bridgecard) for the purpose of issuing and processing virtual dollar cards.
Verification Services: Identity verification platforms (such as Dojah) to validate your government-issued documents against official databases.
Communication Providers: Services (such as Termii) for the delivery of One-Time Passwords (OTPs) and transaction alerts.
5. International Data Transfers
Unlike our domestic services, providing multi-currency accounts requires your data to be processed by international banking intermediaries and cloud infrastructure located outside of Nigeria. We ensure that these partners maintain data protection standards equivalent to the NDPA.
6. Data Retention
We retain your personal and transaction data for at least five (5) years after the termination of your account, or as specifically required by the Central Bank of Nigeria (CBN) and AML regulations.
7. Your Rights
Under the NDPA, you have the right to:
Access your personal data.
Rectify inaccurate information.
Object to certain processing activities.
Request the deletion of your data (subject to legal retention requirements).
8. Security
We implement bank-grade encryption (AES-256) and secure socket layer (SSL) technology to protect your data. Our infrastructure is designed to prevent unauthorized access to your global wallet and sensitive KYC documents.
9. Contact Us
For any privacy-related inquiries regarding the ComePay Multi-Currency app, please contact:
**Data Protection Officer**
Cometstar Technologies Limited
Address: 226, Awolowo Road, Ikoyi Lagos, Nigeria.
Email: privacy@comepayapp.com