Donor information

3.1 Purpose of this Section

This Section explains in detail how the Campaign processes information collected through the donation flow on the Site, and the safeguards we apply. Donor data is handled with a higher standard of care than other categories of personal data because of (a) the sensitivity of political donation data, (b) the regulatory framework around campaign finance in Nigeria, and (c) the cross-border nature of crypto contributions.

3.2 Our payment processor

The Site uses NowPayments OÜ (Estonian company registry no. 14269921; VAT no. EE102036902), a regulated cryptocurrency payment service provider, to generate invoices, accept on-chain transfers, and settle proceeds. NowPayments operates under EU/EEA AML supervision and applies its own KYC/AML controls.

NowPayments acts as an independent controller in respect of the data it is required to process for AML, sanctions screening, and tax reporting. In respect of the specific donation made through the Site, the Campaign and NowPayments are joint controllers within the meaning of Article 26 GDPR. The essence of the joint-controller arrangement is summarised here, and the full arrangement is available on request to contact@peterobi.support.

(a) What NowPayments receives from us

• The contribution amount and currency you selected;
• The cryptocurrency you elected to use;
• The randomly-generated order ID (a ULID) we issued for the contribution;
• An IPN callback URL (a system-to-system endpoint at peterobi.support);
• Optionally, an order description.

(b) What NowPayments returns to us

• An invoice URL and a unique payment ID;
• The pay-to address and the precise crypto amount required;
• Status updates over a webhook (waiting → confirming → confirmed → finished, etc.);
• Reconciliation information allowing the Campaign to credit the contribution to your order ID.

(c) What NowPayments does not receive from us by default

Unless required by law or where you have voluntarily declared the information to us in the donor-details fields, we do not pass to NowPayments your name, email, nationality, or any government-issued identifier.

3.3 KYC and source-of-funds checks

Where a contribution is in scope of the Money Laundering (Prevention and Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, and the Electoral Act 2022(collectively, the “Compliance Acts”), or where it crosses an internal threshold set by the Campaign for risk management, the Campaign may require:

• A copy of a valid government-issued photo identification;
• Proof of residential address dated within the preceding ninety (90) days;
• A signed declaration of source of funds (template provided on request);
• A signed declaration of nationality and (if outside Nigeria) immigration status;
• For contributions in or above the equivalent of USD 1,000, a sanctions and politically-exposed-persons (PEP) screening on the donor name.

Refusal to provide the documents required by the Compliance Acts will result in the Campaign declining the contribution and refunding the underlying transfer to the originating wallet, less unavoidable on-chain network fees.

3.4 INEC reporting and statutory disclosures

The Campaign maintains a contribution register that complies with section 88 and section 89 of the Electoral Act 2022. The register records the date, amount, currency, and (where the contribution is above the published statutory threshold) the donor's name, address, and nationality. The register is filed with the Independent National Electoral Commission (INEC) at the intervals prescribed by law.

Where INEC, the EFCC, the NFIU, or any other authority with statutory power requests donor information, the Campaign discloses only that information that is strictly required to comply with the request and the legal basis for it. Where lawful and not prejudicial to the investigation, the Campaign will notify the affected Data Subject of the disclosure.

3.5 Restrictions on foreign contributions

Section 88(2)(b) of the Electoral Act 2022 prohibits political parties and candidates from accepting contributions from non-Nigerian individuals or organisations. We therefore:

• Require declarations of nationality on donations above an internally-set threshold;
• Reserve the right to refuse, refund, or escrow any contribution where the source jurisdiction is reasonably suspected to be non-Nigerian and the donor has not provided satisfactory evidence of dual citizenship or other lawful basis;
• Maintain a published list of jurisdictions from which we will not accept contributions irrespective of declared nationality (the “Excluded Jurisdictions List”, available on request).

3.6 Anonymity and pseudonymous donations

On-chain transfers may be initiated from wallets that the Campaign cannot link to a natural person. Where such a transfer is received and the contributor cannot be identified, the Campaign will:

1. For amounts below the statutory threshold, treat the contribution as anonymous and publish it as such in the relevant transparency report;
2. For amounts at or above the statutory threshold, place the proceeds in a segregated escrow wallet for ninety (90) days and attempt to identify the donor;
3. Where identification fails after ninety (90) days, refund the contribution to the originating wallet, less network fees;
4. Where refund is technically impossible (for example, because the originating wallet rejects incoming transfers), the Campaign will donate the proceeds to a registered charity nominated by the Authorising Principal and disclose the donation in the next transparency report.

3.7 Donor data security

Donor data receives heightened security treatment, including:

• Encryption at rest using industry-standard ciphers;
• Encryption in transit using TLS 1.2 or higher;
• Strict role-based access control to the donor database;
• Quarterly penetration tests by an independent third-party;
• Mandatory two-factor authentication for any human access;
• Comprehensive audit logging of every read and write operation.

See Section 6 - Security for further detail.

3.8 Donor rights

Donors retain all of the rights set out in Section 4 - Your rights, subject to the legal retention obligations imposed by the Compliance Acts. In particular, the right to erasure does not override our obligation to retain donation records for the periods prescribed by law.