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Internet Banking
Internet Banking

Cookie Policy

HAKKIPAY COOKIE POLICY

Effective Date: 7 August 2026
Last Updated: 7 August 2026
Version: 1.0

  1. Introduction

This Cookie Policy explains how Hakki Solutions Limited, trading as HakkiPay (“HakkiPay”, “we”, “us” or “our”) uses cookies and similar technologies when you visit or interact with our website and other applicable digital platforms.

This Policy should be read together with our Privacy Policy, which explains more broadly how we collect, use, disclose and protect personal data.

HakkiPay is operated by:

Hakki Solutions Limited
RC No. 9477834
Website: www.hakkipay.co

For privacy and data-protection enquiries, please contact:

Data Protection Officer
Email: dpo@hakkipay.co

  1. What Are Cookies?

Cookies are small text files or similar technologies placed on your computer, mobile device or browser when you visit a website.

They may be used to:

  • recognise your device or browser;
  • remember preferences;
  • maintain secure sessions;
  • enable website functionality;
  • understand how visitors use the website;
  • improve performance;
  • detect suspicious or fraudulent activity; and
  • support analytics or other permitted purposes.

Some cookies remain on your device only for the duration of your browsing session, while others remain for a defined period or until deleted.

The Nigeria Data Protection Commission itself describes cookies as files used by websites to remember preferences and improve browsing interactions, and provides users with cookie-management controls on its own website.

  1. Legal Basis and Consent

HakkiPay will use cookies and similar technologies in accordance with applicable Nigerian data-protection requirements.

Under the NDP Act-GAID 2025, the use of cookies on websites and other digital platforms requires appropriate consent where applicable, and consent must be freely given, informed and specific. Users should be provided with a clear option to accept or decline where consent is required.

Accordingly:

  • cookies that are strictly necessary for the basic operation, security or delivery of the website may be used where legally permitted without separate optional consent; and
  • non-essential cookies, such as certain analytics, advertising or personalization cookies, will only be used where the required consent has been obtained.

Where consent is relied upon, you may withdraw or change that consent at any time through the available cookie controls.

  1. Types of Cookies We May Use

The exact cookies used by HakkiPay may change as our website and services evolve.

We may use the following categories.

4.1 Strictly Necessary Cookies

These cookies are required for the website or digital service to function properly.

They may support:

  • secure login;
  • authentication;
  • session management;
  • fraud and security controls;
  • load balancing;
  • navigation;
  • consent-preference storage; and
  • essential technical functionality.

Because these cookies are necessary to provide the service or maintain security, they may not always be capable of being disabled through the website’s cookie controls.

Disabling them through your browser may cause parts of the website to stop functioning correctly.

4.2 Preference or Functional Cookies

These cookies may allow the website to remember choices you make, such as:

  • language preferences;
  • display preferences;
  • region;
  • accessibility settings; or
  • other user preferences.

These cookies help provide a more convenient and personalized experience.

Where consent is required, they will only be activated after you have given the appropriate consent.

4.3 Analytics and Performance Cookies

These cookies help us understand how visitors use the HakkiPay website.

They may provide information about:

  • pages visited;
  • length of visits;
  • navigation patterns;
  • errors;
  • device or browser type;
  • general website performance; and
  • how users interact with features.

We may use this information to improve our website, products and customer experience.

Where these cookies are not strictly necessary, they will be used only in accordance with applicable consent requirements.

4.4 Security and Fraud-Prevention Technologies

We may use cookies or similar technologies to help:

  • identify suspicious access;
  • prevent account abuse;
  • protect login sessions;
  • detect unusual website activity;
  • maintain cybersecurity;
  • protect users; and
  • investigate potential fraud.

Such technologies will be used only to the extent reasonably necessary and lawful for the relevant security purpose.

4.5 Advertising and Marketing Cookies

If HakkiPay uses advertising or marketing technologies in the future, these may be used to:

  • measure advertising performance;
  • understand campaign effectiveness;
  • limit repeated advertising;
  • provide relevant promotional content; or
  • support marketing analytics.

Such cookies will not be activated unless the necessary consent has been obtained.

You may withdraw your consent to marketing cookies at any time.

  1. First-Party and Third-Party Cookies

Cookies may be either:

First-party cookies — set directly by HakkiPay; or

Third-party cookies — set by an external service integrated into our website.

Third-party services may include, where applicable:

  • analytics providers;
  • cloud or security providers;
  • customer-support tools;
  • embedded media providers;
  • marketing platforms; or
  • other technology providers.

Where a third party independently determines how it processes data collected through its technology, its own privacy or cookie policy may also apply.

HakkiPay will seek to use third-party technologies only where reasonably necessary, appropriately assessed and supported by applicable contractual and data-protection safeguards.

  1. Similar Technologies

In addition to cookies, we may use comparable technologies such as:

  • pixels;
  • tags;
  • software development kits;
  • local storage;
  • device identifiers;
  • web beacons; or
  • similar technical mechanisms.

Where such technologies process personal data or require consent, they will be handled in accordance with the same principles described in this Policy and the HakkiPay Privacy Policy.

  1. Cookie Consent Banner

Where non-essential cookies are used, visitors should be presented with a cookie-consent mechanism.

The HakkiPay website should provide options substantially similar to:

Accept All
Reject Non-Essential
Manage Preferences

The cookie banner should not make accepting optional cookies materially easier than rejecting them.

Where consent is required, non-essential cookies should not be activated before the visitor makes the relevant choice.

This approach reflects the GAID requirement that where consent is required, users should have a clear and explicit option to accept or decline.

  1. Managing Your Cookie Preferences

You may manage your cookie choices through the HakkiPay cookie-preference tool where available.

You may also manage or delete cookies through your browser settings.

Depending on your browser, you may be able to:

  • block cookies;
  • delete existing cookies;
  • receive alerts before a cookie is stored; or
  • restrict certain categories of cookies.

Please note that disabling strictly necessary cookies may affect the functionality, security or availability of parts of the website.

  1. Withdrawal of Consent

Where HakkiPay relies on your consent for non-essential cookies, you may withdraw or modify that consent at any time.

Withdrawal of consent does not affect processing that was lawful before the withdrawal.

Your updated preference should apply to future use of applicable optional cookies.

  1. Cookie Retention

Different cookies may remain on your device for different periods.

Session Cookies

These generally expire when you close your browser or browsing session.

Persistent Cookies

These may remain for a defined period unless deleted earlier.

HakkiPay will seek to ensure that cookie retention periods are appropriate to the purpose for which the relevant cookie is used.

Non-essential cookies should not be retained for longer than reasonably necessary for their stated purpose.

  1. Personal Data Collected Through Cookies

Depending on the technology used, cookies and similar technologies may process information such as:

  • IP address;
  • device identifier;
  • browser type;
  • operating system;
  • website activity;
  • session information;
  • referral source;
  • page interactions;
  • preferences; and
  • approximate technical location information.

Where such information constitutes personal data, it will be processed in accordance with the HakkiPay Privacy Policy and applicable Nigerian data-protection law.

  1. International Processing

Some third-party technology providers may operate infrastructure outside Nigeria.

Where information collected through cookies or similar technologies is transferred internationally, HakkiPay will seek to ensure that any transfer of personal data complies with applicable Nigerian data-protection requirements.

Further information about international transfers is provided in the HakkiPay Privacy Policy.

  1. Children’s Privacy

The HakkiPay website and general financial services are not directed at children unless a product expressly states otherwise.

We do not knowingly use cookies for targeted advertising to children through our general services.

If HakkiPay introduces a service specifically intended for minors, additional age, consent and privacy safeguards will be implemented as required by law.

  1. Changes to This Cookie Policy

We may update this Cookie Policy to reflect:

  • changes to the cookies or technologies we use;
  • changes to our website;
  • new services;
  • changes in law or regulation;
  • new regulatory guidance; or
  • changes to our technology providers.

The latest version will be published on www.hakkipay.co and will show the applicable effective date and version number.

Where a material change affects previously given consent, we will take appropriate steps to obtain renewed consent where required.

 

 

  1. Contact Us

If you have questions about this Cookie Policy, the cookies used by HakkiPay or your privacy choices, please contact:

Data Protection Officer
Hakki Solutions Limited / HakkiPay
Email: dpo@hakkipay.co
Website: www.hakkipay.co

General enquiries may be directed to:

info@hakkipay.co

 

HAKKIPAY COOKIE PREFERENCE NOTICE

For the website developer, I recommend the cookie banner itself use simple customer-facing wording such as:

We value your privacy

HakkiPay uses necessary cookies to keep our website secure and functional. With your permission, we may also use optional cookies to understand website performance, remember preferences and improve your experience. You can accept all cookies, reject non-essential cookies or manage your preferences.

Buttons:

Accept All | Reject Non-Essential | Manage Preferences

The Necessary category should show:

Always Active

Optional categories should be switched off by default until consent is given, unless your DPO/legal counsel confirms a different lawful treatment for a specific technology.

One operational caution: before this policy is published, your developer should first produce an actual cookie/technology inventory showing every cookie, SDK, analytics service and third-party tracker running on hakkipay.co. The policy should describe what the website actually uses, not merely what it may use. The NDPC’s own website provides category-based cookie controls and states that users can manage cookie settings, which is a useful benchmark for implementation.

This can be published at www.hakkipay.co/cookies or www.hakkipay.co/cookie-policy