Privacy notice

This notice explains what we collect when you join the TrustAm Data waitlist, use the TrustAm Recorder app or record for us, why we collect it, who we share it with and the choices you have. If we change it, we will show you the new version in the app and ask you to accept it before you record again.

Who controls your data

TrustAm Limited (CAC RC 9391501), Lagos, is the data controller under the Nigeria Data Protection Act 2023. Data protection contact: [email protected].

What we collect

• Your name, phone number, state and LGA, trades, languages and phone model.
• Your BVN or NIN check result, a live selfie for the face match, and your payout account.
• Your consent video and the recordings you make, with motion, location and device data captured alongside them.
• Your device identifier, app version and a security key created on your phone, so we know recordings came from your registered phone.
• Your pay, review results, messages with our support team, and how you heard about us (for example an ad or a friend's referral code).

We only use your camera, microphone, location and motion sensors while you are recording or doing your ID check, and the app tells you when it is recording.

Why we use it

• To check you are a real, single person and pay the right account.
• To review recordings, stop fraud, and pay you.
• To license approved, blurred recordings to companies that train AI, in Nigeria and abroad, as you consented.

Our legal basis

Your consent (given on video, and which you can withdraw), the contract between us so we can review and pay your work, our legal duties (for example anti-money-laundering checks on payouts), and our legitimate interest in stopping fraud.

Who we share it with

• Companies that license approved recordings to train AI. They receive blurred recordings and their metadata, never your name, phone number, ID number or bank details.
• Service providers that work for us: Rubies Microfinance Bank (payouts and ID lookups), Dojah (ID and liveness checks), Cloudflare (storage), Railway (servers), Meta (WhatsApp messages) and SMS providers. They may only use your data to provide their service to us.
• Regulators, the police or courts when the law requires it.

Some of these companies store data outside Nigeria. When data leaves Nigeria we rely on the transfer safeguards in the NDPA 2023 and the NDPC General Application and Implementation Directive.

How we protect it

• BVN and NIN are kept as a scrambled value plus the last four digits. Bank account numbers are encrypted.
• Reviewers see blurred media and never your bank details or full ID number. Every view of raw media is logged.
• Raw recordings are deleted after 90 days unless a buyer contract needs them.
• Data is encrypted in transit and at rest. If a breach puts your data at risk, we tell the NDPC within 72 hours and tell you without delay.

How long we keep it

Waitlist details until you ask us to remove them or 2 years after your last contact. ID check results, payout and pay records for as long as the law requires for financial records. Selfies and ID images are deleted once your check is decided. Licensed recordings stay with the buyer under the licence you agreed to; you can stop future licensing at any time.

Age

TrustAm Data is for adults. You must be 18 or older to join, and the ID check refuses anyone younger.

Your rights

You can see, correct or delete your data, stop future licensing, or complain to the Nigeria Data Protection Commission. Ask us on WhatsApp or by email.

Questions: [email protected] · common questions