Privacy Policy

This Privacy Policy explains how Caesar Tech Limited, operating as "Caesar" ("Caesar", "we", "us", or "our"), collects, uses, stores, and protects personal data when:

• You visit our websites or online properties,
• You use our products and services as a business customer, or
• Your data is processed by Caesar in connection with a platform (for example, an exchange, wallet, or fintech) that uses our services.

We are based in Lagos, Nigeria and focus on crypto tax infrastructure and analytics for platforms and regulators.

If you have any questions, you can contact us using the details in the "Contact us" section.

1. Who we are

Caesar is operated by:

For some activities, Caesar acts as a data controller (for example, for visitors to our website and our own business contacts).

For other activities, especially where we process data on behalf of a platform that has integrated Caesar, we act as a data processor or data sub-processor, following that platform's instructions and applicable data protection law.

2. Scope of this Privacy Policy

This Policy applies to:

• Visitors to our websites and marketing pages
• Representatives and users of our business customers (for example, exchanges, wallets, fintechs, corporate clients)
• End users whose data we process on behalf of a platform that uses Caesar
• Government or regulator contacts where we provide B2G services

It does not apply to websites or services we do not control, including the platforms that integrate our APIs. Those services have their own privacy policies.

3. Personal data we collect

The data we collect depends on how you interact with Caesar.

3.1 Website visitors and marketing contacts

We may collect:

• Contact details – name, email address, company, role, phone number (if you provide them in a form, email, or chat)
• Usage data – pages viewed, clicks, time on page, referring URLs
• Technical data – IP address, browser type and version, device type, operating system, and similar information
• Cookies and similar technologies – see our Cookie Policy for details

3.2 Business customers and partners

When your company signs up for Caesar, we may collect:

• Account and contact data – company name, registration details, billing details, contact persons, login credentials for admin users
• Service usage data – actions taken in the dashboard, configurations, logs relating to your use of the platform

3.3 End users of platforms that integrate Caesar

When a platform (such as an exchange or wallet) uses Caesar, we typically receive pseudonymised or indirect personal data, such as:

• A user reference or identifier used by the platform (not BVN or NIN by default)
• Transaction data – timestamps, event types (for example, buy, sell, trade, deposit, withdrawal, fee, reward, airdrop, interest, NFT trade), assets and amounts, fiat equivalents
• Wallet and technical data – blockchain addresses, chain/network identifiers, and related metadata
• Tax outputs – Caesar's calculated tax positions, confidence scores, flags, and summaries tied to the user reference

We do not request or require passwords, private keys, seed phrases or similar sensitive credentials.

4. How we use personal data

We use personal data for the following purposes:

You can opt out of marketing emails at any time using the unsubscribe link or by contacting us.

5. Legal bases for processing

We rely on different legal bases depending on the context, including:

• Contract – where processing is necessary to perform a contract with you or your organisation, or to take steps at your request before entering into a contract
• Legitimate interests – for example, to improve our services, ensure security, and communicate with existing customers about relevant updates
• Consent – for certain cookies and for specific types of marketing where required by law
• Legal obligation – where we must process data to comply with applicable law, including Nigerian data protection and tax laws

When we act as a processor on behalf of a platform, we rely on that platform's legal basis and follow their instructions and applicable agreements.

6. How we share personal data

We may share personal data with:

Service providers and vendors

Hosting providers, analytics providers, email and communication tools, customer support tooling, and similar vendors who help us deliver the service. These providers are bound by confidentiality and data protection obligations.

Business customers and partners

Where we act as a processor, we provide tax outputs and related data back to the platform that integrated Caesar.

Regulators and authorities

Where we are legally required to do so, or where data sharing is part of a formal B2G engagement with appropriate safeguards.

Professional advisers

Lawyers, auditors, and consultants under appropriate confidentiality obligations.

Corporate transactions

If we engage in a merger, acquisition, financing, or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate safeguards.

We do not sell personal data.

7. International transfers

Caesar Tech Limited is based in Nigeria. Some of our service providers or data storage locations may be outside Nigeria.

Where we transfer personal data across borders, we take reasonable steps to ensure an adequate level of protection, consistent with applicable data protection laws. This may include contractual safeguards or using providers with recognised compliance certifications.

8. Data retention

We retain personal data for as long as reasonably necessary to:

• Provide our services to you or to the platform that engaged us
• Comply with applicable laws (including tax and accounting retention requirements)
• Resolve disputes and enforce our agreements

When data is no longer needed, we will delete or anonymise it, subject to any legal requirements to retain certain records.

9. Your rights

Depending on applicable law and your relationship with us, you may have rights over your personal data, such as:

• Right of access
• Right to rectification
• Right to erasure (subject to legal obligations)
• Right to restriction
• Right to object (including to direct marketing)
• Right to data portability

If your data is processed because a platform uses Caesar, you may need to contact that platform first, as they are typically the primary data controller. We will reasonably assist our customers in responding to data subject requests.

10. Children's data

Caesar is not directed at children. Our services are aimed at businesses, regulators and adult users of financial platforms. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us and we will take appropriate steps.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Effective date" at the top and may provide additional notice (for example, through the service or by email to account owners).

12. Contact us

If you have questions, concerns, or requests about this Privacy Policy, please contact us at: