Privacy Policy

Last updated: October 2026

1. Data We Collect

We collect: identity documents (passport, national ID), selfie/liveness images, email address, phone number, date of birth, country of residence, transaction history, device information, and IP addresses.

2. How We Use Your Data

Your data is used to: verify your identity (KYC), comply with AML/CFT/CPF regulations, process transactions, prevent fraud, communicate with you about your account, and improve our services.

3. Identity Verification

Identity verification is performed by Sumsub (sumsub.com), a regulated identity verification provider. KoinKoin does not store raw identity documents. Processing is compliant with NDPR (Nigeria), DPA (Ghana), and GDPR standards.

4. Face Data (Selfie and Liveness Check)

During identity verification we ask you to take a selfie and complete a short liveness check with your device camera. This face data consists of your selfie image and the liveness capture, from which our identity verification provider Sumsub creates a facial biometric template. We use face data only to confirm that you are a real, present person and that you match the photo on your identity document, as required by anti-money-laundering (AML/CFT) and Know Your Customer (KYC) laws. We do not use face data for advertising, marketing, tracking or analytics, we do not use it to sign you in, and we never sell it. Face data is captured and stored by Sumsub (Sum and Substance Ltd), which processes it on our behalf. Your selfie image is also shared with KuCoin, the regulated exchange and custody partner that operates your trading and deposit account, solely for its own KYC check; KuCoin keeps that copy in line with its own legal record-keeping obligations. KoinKoin does not store face data on your device or on its own servers: when your selfie is passed from Sumsub to KuCoin it is sent over an encrypted connection and is not kept by us. Face data held for KoinKoin is retained for 5 years after your account is closed, as required by Nigerian and Ghanaian AML record-keeping laws, and is then deleted. You can ask us to delete your face data earlier by emailing privacy@koinkoin.com; we will delete it unless the law requires us to keep it, and we will tell you if that is the case.

5. Data Sharing

We share data with: regulatory authorities as required by law, Sumsub for identity verification, KuCoin (our exchange and custody partner) to open and verify your trading and deposit account, our banking partners for fiat processing, and law enforcement when legally required. We do not sell your personal data.

6. Data Retention

We retain your data for a minimum of 5 years after account closure, as required by Nigerian and Ghanaian AML regulations. Identity documents are retained by Sumsub per their data retention policy.

7. Your Rights

You have the right to: access your personal data, correct inaccurate data, request deletion (subject to regulatory retention requirements), object to processing, and data portability. Contact privacy@koinkoin.com to exercise these rights.

8. Security

We use 256-bit SSL encryption, two-factor authentication, cold storage for digital assets, and regular security audits to protect your data.

9. Cookies

We use essential cookies for platform functionality and analytics cookies to improve user experience. See our Cookie Policy for details.

10. Contact

Privacy Officer: privacy@koinkoin.com ยท KoinKoin Global Network Ltd ยท 32C Cameron Road, Ikoyi, Lagos, Nigeria