Nomada

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Privacy Policy

Effective Date: April 27, 2026

1. Introduction

Welcome to W. Pinnacle International Education Ltd. (“Company”, “we”, “us”, or “our”). We operate https://thenomada.com and the Nomada mobile application (collectively, the “Service”).

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service, in compliance with the Nigeria Data Protection Act 2023 and other applicable data protection laws.

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Definitions

  • Service: https://thenomada.com website and Nomada mobile application
  • Personal Data: Any information that identifies an individual
  • Usage Data: Automatically collected data from use of Service
  • Data Controller: W. Pinnacle International Education Ltd.
  • Data Processor: Third parties processing data on our behalf
  • Data Subject: The individual whose data is processed
  • User: Any individual using our Service
  • Chargeback: Reversal of funds initiated by a payer via their bank or card issuer

3. Legal Basis for Processing (NDPA Compliance)

We process Personal Data based on:

  • User consent
  • Performance of a contract
  • Compliance with legal obligations
  • Legitimate business interests (e.g., fraud prevention, service improvement)

4. Information We Collect

4.1 Personal Data

We may collect:

  • Full name
  • Email address
  • Phone number
  • Address details
  • Identification (e.g., BVN, National ID, Passport)
  • Banking/payment-related information (excluding card storage)

4.2 Usage Data

Includes IP address, browser type, device ID, session duration, and interaction data.

4.3 KYC & Compliance Data

To comply with financial regulations, we may collect identity verification data for onboarding merchants and users.

4.4 Cookies and Tracking

We use cookies for:

  • Authentication
  • Preferences
  • Analytics
  • Security

5. How We Use Your Data

We use your data to:

  • Provide and maintain the Service
  • Process transactions and verify users
  • Prevent fraud and abuse (including chargeback fraud)
  • Improve platform performance
  • Communicate updates and support
  • Comply with regulatory requirements

6. Fraud Prevention & Chargeback Monitoring

We implement transaction monitoring systems to detect suspicious activity.

We reserve the right to:

  • Investigate disputed transactions
  • Restrict accounts linked to fraudulent chargebacks
  • Share relevant data with financial institutions and regulators where required

7. Data Retention

We retain Personal Data:

  • As long as necessary for service delivery
  • As required by law (e.g., financial record retention obligations)
  • For dispute resolution and fraud prevention

8. Data Sharing and Disclosure

We may share your data with:

  • Payment processors and financial institutions
  • Regulatory authorities and law enforcement
  • Service providers (under strict confidentiality agreements)

We do not sell personal data.

9. International Data Transfers

Your data may be processed outside Nigeria. Where this occurs, we ensure:

  • Adequate data protection safeguards
  • Compliance with NDPA cross-border transfer requirements

10. Data Security

We implement:

  • Encryption
  • Access controls
  • Secure infrastructure

However, no system is completely secure.

11. Your Rights (Under NDPA & GDPR Principles)

You have the right to:

  • Access your data
  • Correct inaccurate data
  • Request deletion
  • Restrict processing
  • Object to processing
  • Withdraw consent

To exercise your rights, contact: support@thenomada.com

12. Data Deletion Requests

You may request deletion by emailing support@thenomada.com with the subject: “Data Deletion Request”.

We will:

  • Verify your identity
  • Process requests within 21 working days
  • Retain data where legally required

13. Third-Party Services

We may use:

  • Analytics tools (e.g., Google Analytics)
  • Cloud infrastructure providers
  • Payment processors (PCI-DSS compliant)

We are not responsible for third-party privacy practices.

14. Children’s Privacy

Our Service is not intended for individuals under 13. We do not knowingly collect data from children.

15. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be communicated via:

  • Website notice
  • Email (where applicable)

16. Contact Information

For questions or data requests:

W. Pinnacle International Education Ltd.

Email: support@thenomada.com

17. Regulatory Contact (Nigeria)

If you are unsatisfied with our response, you may contact the Nigeria Data Protection Commission.