Welcome to KOLOWISE.
KOLOWISE is a personal finance application designed to help users save intentionally and manage spending through structured financial products. Our core promise is: “Kolowise helps you control your money before your money controls you.”
This Privacy Policy explains how Kolowise Partners, operating as KOLOWISE, collects, uses, stores, protects, and shares personal data when you use the KOLOWISE mobile application and related services.
KOLOWISE operates in Nigeria and currently provides personal finance services to eligible Nigerian residents aged 18 and above.
KOLOWISE is not itself the entity that holds or safeguards customer funds. Customer funds are held through our regulated financial infrastructure partner, Anchor, subject to the applicable contractual and regulatory arrangements.
This Privacy Policy should be read together with the KOLOWISE Terms & Conditions.
Legal entity: Kolowise Tech Ltd
CAC Registration Number: 9594478
Registered Address: FLAT 7, BLOCK DSP, SOUTHPOINTE ESTATE, ORCHID ROAD, LEKKI, LAGOS STATE, NIGERIA
Country of operation: Nigeria
KOLOWISE operates through regulated financial infrastructure provided by Anchor. Anchor is responsible for the relevant regulated wallet/account infrastructure, custody of customer funds, and applicable KYC/AML decisioning within the arrangement between the parties.
KOLOWISE remains responsible for the operation of the KOLOWISE application, and for the personal data processing it determines for its services.
This Privacy Policy applies to individuals who:
KOLOWISE currently does not offer business or corporate accounts.
You must be at least 18 years old and a resident in Nigeria to use KOLOWISE.
Depending on your use of KOLOWISE, we may collect the following categories of information.
This may include:
Additional information may be requested where Enhanced Due Diligence (EDD) is required.
We may collect:
Passwords and PINs are not intended to be stored in plain text.
When you use KOLOWISE, we may process:
Customer funds are held through the applicable regulated financial infrastructure provided by Anchor.
We may collect technical information such as:
KOLOWISE may request camera access when necessary for:
Camera access is not intended to be required for every user.
KOLOWISE does not currently require access to:
Biometric/liveness data may be processed through our identity-verification provider. The precise storage and deletion practices of the provider regarding biometric/liveness information are subject to confirmation.
KOLOWISE may process location-related information where necessary for analytics, security, fraud prevention, regulatory or service purposes. Where precise location is not required for a specific service, KOLOWISE will seek to avoid unnecessary collection.
We may collect information contained in communications between you and KOLOWISE, including:
KOLOWISE uses third-party providers and infrastructure to operate parts of its service. These currently include:
QoreID is not currently part of the KOLOWISE implementation.
We may collect information:
KOLOWISE may process personal data for the following purposes.
To comply with applicable:
We use Google Analytics for Firebase to understand how the app is used. We may process technical and operational information to:
KOLOWISE currently uses Sentry for crash reporting and Firebase for push notifications.
Depending on the circumstances, KOLOWISE may process personal data based on:
We do not rely on consent where another lawful basis legitimately permits the processing. Where processing depends on consent, you may withdraw consent subject to applicable legal limitations and the consequences of doing so.
KOLOWISE operates a progressive verification model.
Depending on the applicable onboarding path, this may include:
Additional information may include:
Where risk requires additional verification, KOLOWISE or its regulated partners may request:
A PEP is not automatically excluded solely because of PEP status. A PEP may be subject to Enhanced Due Diligence and enhanced monitoring.
KOLOWISE may use automated rules and risk signals to support decisions relating to:
The current KOLOWISE design does not specify a standalone numerical risk score. Automated processing may be supplemented by manual review where appropriate.
Where applicable law provides rights concerning decisions based solely on automated processing, KOLOWISE will apply the relevant safeguards, including applicable rights to human intervention, to express a view and to contest a decision.
Service providers who process data on our behalf, We do not share your personal data with third parties for their own purposes. We use service providers who process data strictly on our instructions. These may include:
Anchor provides the regulated financial infrastructure through which customer funds are held, and money movement occurs. Anchor may also be responsible for applicable KYC/AML decisioning.
Prembly may process information required for identity verification, KYC, AML, sanctions, PEP, fraud or related compliance services.
KOLOWISE uses infrastructure and technology providers, including Railway and AWS infrastructure, for application hosting and related technical services, subject to the actual technical configuration.
We may use other service providers where necessary for:
We do not sell or rent your personal data to third parties for advertising.
Some technology or service providers used by KOLOWISE may process or store information outside Nigeria. KOLOWISE currently uses cloud infrastructure involving AWS infrastructure in the EU through its deployment environment.
Where personal data is transferred outside Nigeria, KOLOWISE will apply the safeguards and lawful mechanisms required by applicable Nigerian data-protection law.
The exact list of cross-border processors, locations and transfer mechanisms remains subject to final technical and legal confirmation before publication.
KOLOWISE does not retain personal data indefinitely. We retain information for periods appropriate to:
As a working compliance policy, specified transaction, customer-identification and AML records will generally be retained for at least five years, or longer where applicable law, regulatory requirements or provider obligations require longer retention.
Support and communication records may be retained for as long as reasonably necessary to:
Security and audit information may be retained for the period necessary to protect the service, investigate incidents, and meet applicable obligations.
Marketing preferences and relevant records may be retained while necessary to manage your communication preferences and demonstrate compliance with applicable requirements.
Closing your account does not necessarily result in immediate deletion of all personal data. Some information will continue to be retained where necessary for compliance, fraud prevention, financial records, dispute resolution, legal claims or other lawful purposes.
You can delete your account in the app at Profile → Security → Delete Account. If you no longer have the app or cannot sign in, email hello@kolowise.com from your registered email address, or use this link: https://www.kolowise.com/delete-account.
Deletion is permanent. Withdraw any remaining balance and close active vaults first, as funds in a closed account cannot be recovered.
We delete your profile, saved bank details and vaults. Identity and transaction records are retained for the periods required by law, and are used only to meet those obligations. Where information is no longer required, we delete or anonymise it in accordance with our retention procedures.
Subject to applicable law and legitimate restrictions, you may have rights including:
The Nigeria Data Protection Commission recognises these categories of data-subject rights under the Nigeria Data Protection Act.
For privacy and data-subject requests, users should contact KOLOWISE through the general customer-support channel.
Customer Support / Privacy Contact: hello@kolowise.com · +234 902 070 0831 · 07043033872
KOLOWISE may require reasonable information to verify your identity before processing a request. We aim to respond to valid data-subject requests within 30 days, subject to applicable law, complexity and any lawful extension or limitation.
We may refuse or limit a request where permitted or required by law, including where fulfilling the request would compromise another person's rights, legal obligations, fraud investigations, AML requirements or required record retention.
KOLOWISE may send:
Marketing communications will have an appropriate opt-out mechanism.
You may withdraw from marketing communications without affecting essential service or security communications.
KOLOWISE uses Firebase for push notifications. Notifications may include information relating to:
You can manage notification permissions through your device settings, although disabling certain notifications may affect your ability to receive important service or security alerts.
KOLOWISE uses reasonable technical and organisational safeguards designed to protect personal data against:
No digital service can guarantee absolute security.
You are responsible for protecting your credentials, PIN, password and device and for reporting suspected compromise promptly.
If your registered device is lost, stolen or compromised, you should notify KOLOWISE as soon as reasonably possible. KOLOWISE may:
You should also promptly report any transaction that you believe was unauthorised.
KOLOWISE may disclose personal information where required or permitted by law. This may include disclosures to:
KOLOWISE may be required to report or respond to matters involving suspected fraud, money laundering, terrorist financing, sanctions, suspicious transactions or other unlawful activity. Where disclosure to you could compromise an investigation or is prohibited by law, KOLOWISE may not be able to provide details.
KOLOWISE maintains procedures for responding to personal-data and security incidents. Where a data breach creates obligations to notify regulators or affected individuals, KOLOWISE will make notifications in accordance with applicable Nigerian data-protection requirements.
KOLOWISE is intended for individuals aged 18 years and above.
KOLOWISE does not knowingly provide accounts to minors.
If we become aware that an account has been created by a person below the minimum eligible age, we may restrict or close the account and take appropriate steps regarding the associated data.
KOLOWISE may update this Privacy Policy when:
The updated version will be made available through the KOLOWISE application or another appropriate channel. The effective date at the beginning of this Policy indicates the latest version.
Kolowise Tech Ltd, RC 9594478
FLAT 7, BLOCK DSP, SOUTHPOINTE ESTATE, ORCHID ROAD, LEKKI, LAGOS STATE, NIGERIA
Customer Support / Privacy Requests: hello@kolowise.com
Effective Date: 14 September 2026