Section 01
Who we are
"tewo" refers to the operating entity that publishes the tewo mobile app and the website at www.tewoapp.com. We act as the data controller for personal data processed in connection with your tewo account.
For any privacy question, including the requests in §9, reach us at privacy@tewoapp.com.
Section 02
Data we collect
We collect only what we need to run the service and meet our regulatory obligations. By category:
- Account
- Email, full name, date of birth, country (NG / GH at launch), and the 6-digit transaction PIN you set. The PIN is one-way hashed (bcrypt cost-12) — we never see the cleartext.
- Phone number
- Either your home country number or your Chinese (+86) number, used for OTP delivery and recovery. You pick which one in the app; we store whichever you confirm.
- Identity verification
- For tier-up beyond T1, your government-issued identifier (BVN/NIN for Nigeria; Ghana Card / SSNIT for Ghana) plus address confirmation at T3. These are verified by Prembly; we keep the match result and the document reference, not the raw scan content.
- Alipay binding
- When you sign in with Alipay, the OAuth grant gives us your Alipay open_id. That's the value we later use as the payout target. We do not get your Alipay password, your bank cards, or your contacts.
- Transactions
- Quotes, orders, funding events, payout events, support thread messages. Each transaction carries the amount, currency, timestamp, and the provider reference (Flutterwave, Paystack, Alipay).
- Device & technical
- Device model, OS version, app version, push token (Expo), IP at request time, anonymous crash logs. Used for delivery, security and debugging.
Section 03
Where we get it
- Directly from you — what you type during signup, KYC, and order entry.
- From Alipay — your
open_idand basic profile through the OAuth consent you grant at sign-in. - From Prembly — KYC match results when you submit BVN / NIN / Ghana Card / SSNIT.
- From Flutterwave & Paystack — funding confirmations (amount, reference, timestamp) when your sponsor pays into your virtual account.
- Automatically — device, network and crash data the app sends to keep itself working.
Section 04
How we use it
- Run the service — issue quotes, create virtual accounts, reconcile funding, dispatch the Alipay Merchant Transfer to your bound wallet, send you status updates.
- Comply with regulation — KYC / AML, sanctions screening, per-student tier limits, transaction monitoring, suspicious-activity reporting where required by law.
- Prevent fraud — detect anomalous funding patterns, lock accounts on suspicious activity, support chargeback investigations.
- Support you — answer in-app and email tickets, investigate failed payouts.
- Improve the product — aggregate, de-identified analytics on which flows succeed and where users get stuck.
We do not sell your personal data and we do not show third-party advertising inside the app.
Section 06
International transfers
Because tewo connects African senders to Chinese settlement, your data necessarily moves between jurisdictions. Specifically:
- Account and operational data is stored in MongoDB Atlas Frankfurt (EU).
- KYC verification happens against Prembly (Nigeria).
- Funding metadata flows through Flutterwave (NG) or Paystack (GH).
- The payout call carries your
open_idand amount to Alipay (PRC).
We use standard contractual clauses or equivalent safeguards with our processors where applicable, and we only transfer what the receiving processor needs to do its job.
Section 07
How long we keep it
- Transaction records
- Retained for 7 years from the date of the transaction, in line with African AML record-keeping rules. This applies even if you delete your account.
- Account data
- Kept while your account is active. After closure, retained for the same 7-year window for the transactions you ran, then deleted.
- Support threads
- Retained for 3 years from the date of the last message.
- Push tokens & device data
- Cleared within 30 days of inactivity or app uninstall.
Section 08
How we secure it
- TLS 1.2+ in transit for every API call.
- Bcrypt cost-12 hashing for transaction PINs; PINs never logged.
- Sessions via better-auth with CSRF-strict origin enforcement.
- Biometric unlock + auto-lock on app background.
- Tier-locked daily and per-transaction caps, enforced server-side.
- Payout payee is always your bound Alipay open_id — loaded server-side, never accepted from the client.
- Append-only audit log on every state transition.
Section 09
Your rights
You can ask us to:
- Access — a copy of the personal data we hold on you.
- Correct — fix anything that's wrong or out of date.
- Delete — close your account and erase your data, subject to records we're legally required to keep (transaction records, see §7).
- Restrict or object — to specific processing where the law allows.
- Portability — receive your data in a structured, machine-readable format.
- Withdraw consent — for anything we asked your consent for, going forward.
Email privacy@tewoapp.com. We'll respond within 30 days. You also have the right to complain to your local data protection authority (NDPC in Nigeria, DPC in Ghana).
Section 10
Children
tewo is not for anyone under 18. We don't knowingly collect data from people under 18. If you believe a minor has signed up, email us and we'll close the account.
Section 11
Changes to this policy
We update this policy when our practices change. The "Last updated" date at the top is authoritative. If a change is material (e.g. a new processor, a new data category), we'll let you know in-app and by email before it takes effect.
Section 12
Contact
- Privacy questions
- privacy@tewoapp.com
- Security incidents
- security@tewoapp.com
- General support
- support@tewoapp.com