Privacy policy

Draft — pending legal review. Draft structure under the Nigeria Data Protection Act 2023, for a Nigerian lawyer and our DPO to write. Not legal text.

  1. Data controller

    [Company name] Ltd; NDPC registration as a data controller of major importance [number]; Data Protection Officer [name, email].

  2. What we collect

    Name, phone, email; NIN or BVN result from our identity provider; bank account details; linked social handles and public post statistics; device and network data used for fraud checks.

  3. Why, and on what lawful basis

    Running your account (contract), paying you and stopping fraud (legitimate interest, legal obligation), marketing only with consent.

  4. Who we share it with

    Identity verification, payment and payout providers, hosting; brands see your public handle and post statistics only [confirm].

  5. Transfers outside Nigeria

    Where data is processed abroad and the safeguard used (adequacy, standard contractual clauses) [list providers and countries].

  6. How long we keep it

    Financial records [years]; identity results [years]; closed accounts [period].

  7. Your rights

    Access, correction, deletion, portability, objection, withdrawing consent, and not being subject to purely automated decisions; a person reviews every fraud penalty.

  8. Security

    Encryption, access controls, breach notification to the NDPC within 72 hours.

  9. Complaints

    Contact our DPO first; you may complain to the Nigeria Data Protection Commission.

  10. Cookies

    What we use and how to opt out [confirm].