Your Privacy, Protected.
Introduction
Haulscape Technologies Ltd, trading as MyCut ("MyCut", "we", "our", "us"), is committed to protecting your personal data. This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, and your rights regarding your data.
MyCut is a deal execution and payment disbursement platform built for multi-party transactions in Nigeria. Our platform allows users to negotiate, agree, and automatically execute financial deals.
This policy applies to all users of the MyCut mobile application, website (mycut.biz), and related services. By using MyCut, you agree to the collection and use of information as described in this policy.
Company Information
| Registered Name | Haulscape Technologies Ltd |
| Trading Name | MyCut |
| Company Number | 15245660 |
| Registered Address | 31 Bath Close, London, England, SE15 2JP, United Kingdom |
| Operational Address | 4 Iwowari Avenue, Peter Odili Road, Port Harcourt, Rivers State, Nigeria |
| Data Controller | Tamunotonye Ibisiki |
| Support Email | support@mycut.biz |
| Phone | +234 818 293 1756 |
| Website | mycut.biz |
Data We Collect
3.1 Identity and Contact Data
- Full name
- Email address
- Phone number
- Profile photograph (optional)
3.2 Identity Verification Data (KYC)
- Bank Verification Number (BVN) — collected via 9PSB's licensed infrastructure
- National Identification Number (NIN) — for Tier 2 and above deals
- Government-issued ID document — for Tier 3 / corporate deals
- Liveness verification data (for high-value transactions)
Important: BVN and NIN are processed exclusively through 9 Payment Service Bank (9PSB), a CBN-licensed institution. MyCut does not store raw BVN or NIN numbers on our servers. These are passed directly to 9PSB's secure KYC infrastructure.
3.3 Transaction Data
- Deal terms: roles, split percentages, naira amounts
- Negotiation history and timestamped activity logs
- Consent records and confirmation timestamps
- Virtual account details generated per deal
- Payment and disbursement records
3.4 Device and Technical Data
- Device identifiers (for fraud detection on high-value deals)
- IP address
- App version and operating system
- Session activity logs
3.5 Data We Do NOT Collect
- We do not collect your contacts list
- We do not access your photos or media
- We do not collect your precise GPS location
- We do not collect call logs
- We do not collect biometric data beyond liveness checks on high-value deals
How We Use Your Data
| Purpose | Legal Basis |
|---|---|
| KYC verification and identity confirmation | Legal obligation (CBN KYC requirements) |
| Creating and managing your deal room | Performance of contract |
| Processing and disbursing payments | Performance of contract |
| Generating the negotiation audit trail | Legal obligation / Legitimate interest |
| Fraud detection and security monitoring | Legitimate interest / Legal obligation |
| Customer support and dispute resolution | Legitimate interest |
| Regulatory reporting to CBN | Legal obligation |
| Platform improvement and analytics | Legitimate interest |
| Sending deal invitations to co-parties | Performance of contract |
Data Security
We implement the following security measures to protect your personal data:
- All data is encrypted in transit using TLS 1.2 or higher
- Data at rest is encrypted using AES-256 encryption
- BVN and NIN are never stored in plain text on MyCut servers
- Access to personal data is restricted to authorised personnel only
- Device fingerprinting and behavioural anomaly detection are applied on high-value deals
- Regular security audits are conducted on our infrastructure
While we implement industry-standard security measures, no system is completely secure. If you suspect your account has been compromised, contact us immediately at support@mycut.biz.
Data Retention
We retain your personal data for the following periods:
| Data Type | Retention Period |
|---|---|
| Deal records and audit trails | 7 years from deal completion (CBN financial record-keeping) |
| KYC documents | 5 years after account closure (CBN AML/CFT guidelines) |
| Transaction logs | 5 years |
| Account data | Duration of account plus 2 years after closure |
| Support communications | 3 years |
When retention periods expire, data is securely deleted or anonymised.
Your Rights
Under the Nigeria Data Protection Act 2023 (NDPA) and the UK General Data Protection Regulation (UK GDPR), you have the following rights:
Right of Access
Request a copy of the personal data we hold about you.
Right to Rectification
Request correction of inaccurate data.
Right to Erasure
Request deletion of your data, subject to legal retention obligations.
Right to Restrict Processing
Request we limit how we use your data.
Right to Data Portability
Receive your data in a structured, machine-readable format.
Right to Object
Object to processing based on legitimate interests.
To exercise any of these rights, contact us at support@mycut.biz. We will respond within 30 days. Some rights are subject to legal obligations — for example, we cannot delete deal records we are required to retain under CBN regulations.
Children's Privacy
MyCut is strictly for users aged 18 and above. We do not knowingly collect personal data from anyone under 18. If you believe a minor has created an account on MyCut, contact us immediately at support@mycut.biz and we will delete the account and all associated data.
International Data Transfers
MyCut operates from both the United Kingdom and Nigeria. Data may be processed and stored in both jurisdictions. Where data is transferred from Nigeria to the UK, or vice versa, we ensure appropriate safeguards are in place in compliance with the NDPA 2023 and UK GDPR.
Our infrastructure partners (9PSB and Fincra) process data within Nigeria in accordance with CBN regulations.
Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you via the MyCut app and by email to the address registered on your account at least 14 days before the changes take effect. Your continued use of MyCut after the effective date constitutes acceptance of the updated policy.
The latest version of this policy is always available at mycut.biz/privacy.
Contact and Complaints
For any privacy-related questions, requests, or complaints:
- Email: support@mycut.biz
- Phone: +234 818 293 1756
- UK Address: 31 Bath Close, London, England, SE15 2JP
- Nigeria Address: 4 Iwowari Avenue, Peter Odili Road, Port Harcourt, Rivers State
If you are unsatisfied with our response, you have the right to lodge a complaint with:
- Nigeria Data Protection Bureau (NDPB) — ndpb.gov.ng
- UK Information Commissioner's Office (ICO) — ico.org.uk (for UK users)