Privacy Policy

1. Introduction

Sure Cashback ("Sure Cashback", "we", "us", or "our") is a cashback and rewards platform that

enables customers to earn, track, and redeem cashback from participating businesses, merchants,

corporate partners, franchises, and associations.

This Privacy Policy explains how we collect, use, store, share, and protect your personal

information when you use the Sure Cashback platform and related services.

2. Information We Collect

Depending on how you use Sure Cashback, we may collect:

Personal Information

• Full name (first name, middle name where provided, and last name)
• Email address
• Phone number
• Contact and profile information
• Account credentials
• Cluster or association membership information

Identity and Verification Information

• Identification information and documents required for KYC
• Business registration and compliance documents for merchants and organizations
• Other information required for identity or business verification

Transaction and Cashback Information

• Purchases and transaction history
• QR Code transactions
• Cashback earned, pending, redeemed, expired, reversed, or cancelled
• Digital receipts
• Wallet activity
• Refund and settlement records

Technical Information

• IP address
• Device and browser information
• Login and activity information
• Cookies and similar technologies
• Location information where permission has been granted, such as for nearby merchant discovery

3. How We Use Your Information

We may use your information to:

• Create and manage your account
• Authenticate and verify users
• Conduct KYC, KYB, and compliance checks
• Calculate, credit, and redeem cashback
• Maintain cashback wallets
• Validate QR Code transactions
• Process refunds, reversals, and settlements
• Manage rewards, referrals, promotions, and cashback campaigns
• Recommend participating merchants and offers
• Provide transaction and cashback notifications
• Provide customer support and resolve disputes
• Detect and prevent fraud and suspicious activity
• Conduct AML and compliance monitoring
• Generate reports and improve our Services
• Meet legal and regulatory obligations

4. Cashback Wallet and Transactions

Sure Cashback processes transaction and wallet information to calculate cashback, maintain balances,

process redemptions, validate transactions, and manage refunds or reversals.

Cashback may remain pending until the underlying transaction has been successfully validated.

Where a purchase is cancelled, refunded, reversed, or found to be invalid, the associated cashback

may also be adjusted or reversed.

5. Location Information

Where you grant permission, Sure Cashback may use your location to help you discover nearby

participating merchants and relevant cashback offers.

You can manage location permissions through your device settings.

6. How We Share Information

We may share information where necessary with:

• Participating merchants and corporate partners
• Franchise and dealer outlets
• Clusters and associations
• Payment and settlement providers
• Identity and business verification providers
• Compliance and fraud-prevention providers
• Technology and infrastructure providers
• Regulatory or government authorities where legally required
• Other service providers necessary to operate Sure Cashback

We do not sell your personal information.

7. Marketing and Communications

We may send:

• Transaction notifications
• Cashback and expiry notifications
• Account and security alerts
• Service announcements
• Promotional offers and campaigns
• In-app, SMS, email, or push notifications

Where required by applicable law, promotional communications will be sent based on the appropriate

consent, and users may manage their communication preferences.

8. Data Security

We use reasonable technical and organizational safeguards designed to protect personal information

from unauthorized access, loss, misuse, alteration, or disclosure.

These may include authentication controls, access restrictions, security monitoring, and audit logs.

However, no electronic system can guarantee absolute security.

9. Data Retention

We retain personal information only for as long as necessary to:

• Provide our Services
• Maintain transaction and cashback records
• Resolve disputes
• Prevent and investigate fraud
• Meet accounting, legal, regulatory, and compliance requirements

Information that is no longer required may be securely deleted or anonymized.

10. Your Privacy Rights

Subject to applicable data protection laws, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of eligible information
• Restrict or object to certain processing
• Withdraw consent where processing is based on consent
• Request eligible information in a portable format
• Lodge a complaint with an appropriate data protection authority

Certain information may be retained where required by law or necessary for regulatory,

fraud-prevention, financial, or dispute-resolution purposes.

11. Cookies and Third-Party Services

Sure Cashback may use cookies and similar technologies to authenticate users, maintain secure

sessions, understand platform usage, improve performance, and prevent fraud.

We may also integrate with third-party payment, verification, communication, analytics, and

technology providers. Their own privacy policies may apply when you interact directly with their

services.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our Services, business practices, or legal

requirements.

Material changes may be communicated through the platform, email, or other appropriate channels.

13. Contact Us

For questions, complaints, or requests concerning this Privacy Policy or your personal information,

please contact:

Sure Cashback

• Email: support@surecashback.com
• Address: Lagos, Nigeria