Privacy Policy

1. Introduction

Welcome to NigeriaCreators ("we," "us," "our," or "the Platform"). We are committed to protecting your privacy and ensuring the security of your personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable Nigerian data protection regulations.

This Privacy Policy explains:

• What personal data we collect from you
• How and why we collect and use your data
• Who we share your data with
• How we protect your data
• Your rights regarding your personal data
• How to contact us about privacy concerns

By using NigeriaCreators, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy.

If you do not agree with this Privacy Policy, please do not use our Platform.

2. Data Controller Information

For the purposes of the Nigeria Data Protection Act (NDPA) 2023, the data controller is:

NigeriaCreators
Email: privacy@nigeriacreators.com.ng
Data Protection Officer: dpo@nigeriacreators.com.ng
Address: [Insert Physical Address in Nigeria]
Website: https://www.nigeriacreators.com.ng/

If you have any questions or concerns about how we handle your personal data, please contact our Data Protection Officer using the contact details above.

3. Legal Basis for Processing Personal Data

We process your personal data in accordance with the Nigeria Data Protection Act (NDPA) 2023. We collect and process your personal data based on one or more of the following legal grounds:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract Performance: Processing is necessary to fulfill our contractual obligations to you or to take steps at your request before entering into a contract
• Legal Obligation: Processing is necessary to comply with Nigerian laws and regulations
• Legitimate Interests: Processing is necessary for our legitimate business interests, provided these do not override your fundamental rights and freedoms

Where we rely on your consent, you have the right to withdraw it at any time by contacting us.

4. Personal Data We Collect

We collect different types of personal data depending on how you interact with our Platform:

4.1 Information You Provide Directly

Account Registration Data:

• Full legal name
• Email address
• Phone number
• Username and password
• Date of birth (for age verification)
• Profile photograph (optional)
• Professional or business information (for creators)
• Bank account details or payment information (for creators receiving payments)

Profile and Content Data:

• Biographical information
• Portfolio or creative work samples
• Posts, comments, and messages
• Reviews and ratings
• Subscription preferences

Communication Data:

• Messages sent through our Platform
• Customer support inquiries and correspondence
• Survey responses and feedback
• Newsletter and marketing preferences

Transaction Data:

• Purchase history
• Subscription details
• Payment amounts and dates
• Invoices and receipts

4.2 Information Collected Automatically

Device and Technical Data:

• IP address and device identifiers
• Browser type and version
• Operating system
• Device model and manufacturer
• Screen resolution
• Language preferences
• Time zone settings

Usage and Analytics Data:

• Pages visited and features used
• Time spent on the Platform
• Click patterns and navigation paths
• Search queries
• Referral sources (how you found our Platform)
• Date and time of access
• Error logs and diagnostic data

Location Data:

• Approximate geographic location based on IP address
• Precise location data (only if you grant permission)

4.3 Payment Information

Important: We do NOT directly collect, process, or store your complete payment card details, bank account numbers, or card security codes (CVV).

Payment information is collected and processed by our authorized third-party payment service providers, including:

• Flutterwave
• Paystack
• Other licensed payment processors operating in Nigeria

When you make a payment, you will be directed to the payment processor's secure interface. The payment processor collects:

• Card number, expiration date, and CVV
• Cardholder name
• Billing address
• Bank account details (for bank transfers)

We may receive and store limited payment information from our payment processors, such as:

• Last four digits of your card
• Card type (Visa, Mastercard, Verve)
• Payment confirmation details
• Transaction reference numbers
• Payment status

This limited information helps us provide customer support, process refunds, and maintain transaction records.

4.4 Information from Third Parties

We may receive information about you from:

• Payment processors (transaction confirmations, fraud alerts)
• Social media platforms (if you choose to link your accounts)
• Analytics providers
• Marketing partners
• Publicly available sources

4.5 Sensitive Personal Data

We generally do not collect sensitive personal data (such as health information, religious beliefs, or biometric data) unless specifically required for certain features and with your explicit consent.

5. How We Use Your Personal Data

We use your personal data for the following purposes:

5.1 Account Management and Service Delivery

• Creating and managing your account
• Authenticating your identity
• Providing access to Platform features and services
• Personalizing your experience
• Processing subscriptions and memberships
• Facilitating connections between creators and users

5.2 Payment Processing and Financial Transactions

• Processing payments for services, subscriptions, or purchases
• Facilitating payments to creators
• Issuing invoices and receipts
• Processing refunds and chargebacks
• Preventing fraud and unauthorized transactions
• Maintaining financial records

5.3 Communication

• Sending transactional emails (account confirmations, password resets, receipts)
• Responding to your inquiries and support requests
• Sending service updates and announcements
• Sending newsletters and promotional content (with your consent)
• Conducting surveys and requesting feedback
• Notifying you of new features or changes to our services

5.4 Platform Improvement and Analytics

• Analyzing usage patterns and trends
• Conducting research and development
• Testing new features and improvements
• Monitoring Platform performance and stability
• Identifying and fixing technical issues
• Optimizing user experience

5.5 Security and Fraud Prevention

• Detecting and preventing fraud, scams, and abuse
• Protecting against security threats and unauthorized access
• Investigating suspicious activities
• Enforcing our Terms of Service
• Protecting our rights and property

5.6 Legal Compliance and Protection

• Complying with Nigerian laws and regulations
• Responding to legal requests from authorities
• Establishing, exercising, or defending legal claims
• Protecting the rights, safety, and property of our users
• Complying with tax and accounting requirements

5.7 Marketing and Advertising

• Displaying personalized content and recommendations
• Serving targeted advertisements (with your consent)
• Measuring advertising effectiveness
• Building customer profiles for marketing purposes
• Promoting our services and partners

You can opt out of marketing communications at any time by clicking the "unsubscribe" link in our emails or adjusting your account settings.

6. How We Share Your Personal Data

We respect your privacy and only share your personal data in the following circumstances:

6.1 Third-Party Service Providers

We share personal data with trusted service providers who assist us in operating our Platform:

Payment Processors:

• Flutterwave, Paystack, and other authorized payment gateways
• These providers process payments on our behalf and are bound by strict security and confidentiality obligations
• They operate under their own privacy policies and data protection standards

Technology and Infrastructure Providers:

• Cloud hosting services (e.g., AWS, Google Cloud, Microsoft Azure)
• Content delivery networks (CDNs)
• Database management services
• Email service providers
• Customer relationship management (CRM) platforms

Analytics and Performance Tools:

• Google Analytics or similar analytics platforms
• Performance monitoring tools
• Heat mapping and user behavior analysis tools

Communication Services:

• Email delivery platforms
• SMS and notification services
• Customer support software

Security Services:

• Fraud detection and prevention services
• Identity verification services
• Cybersecurity monitoring tools

All service providers are carefully selected and contractually required to:

• Use your data only for specified purposes
• Implement appropriate security measures
• Comply with applicable data protection laws
• Not disclose your data to unauthorized parties

6.2 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and any choices you may have.

6.3 Legal Authorities and Compliance

We may disclose your personal data to Nigerian law enforcement, regulatory authorities, courts, or government agencies when:

• Required by Nigerian law or legal process
• Responding to valid legal requests (court orders, subpoenas, warrants)
• Investigating potential violations of our Terms of Service
• Protecting the rights, safety, or property of NigeriaCreators, our users, or the public
• Preventing fraud, security threats, or illegal activities
• Complying with tax, accounting, or regulatory obligations

6.4 Public Information

Information you choose to make public on your profile, such as your name, profile picture, biography, and creative work, may be visible to other users and the general public. Please exercise caution when deciding what information to share publicly.

6.5 With Your Consent

We may share your personal data with other parties when you have given us explicit consent to do so.

6.6 Aggregate and De-identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you. This data may be used for research, analytics, reporting, or marketing purposes.

7. Cookies and Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They help websites remember your preferences, analyze usage, and provide personalized experiences.

7.2 Types of Cookies We Use

Essential Cookies:

• Required for the Platform to function properly
• Enable account login and authentication
• Remember your preferences and settings
• Maintain security and prevent fraud
• Cannot be disabled without affecting Platform functionality

Performance and Analytics Cookies:

• Collect information about how you use the Platform
• Track page views, time spent, and navigation patterns
• Help us identify technical issues
• Improve Platform performance and user experience

Functionality Cookies:

• Remember your choices and preferences
• Personalize content and features
• Enable social media integration
• Provide enhanced services

Marketing and Advertising Cookies:

• Deliver targeted advertisements based on your interests
• Track advertising campaign effectiveness
• Build user profiles for marketing purposes
• Limit how many times you see an advertisement

7.3 Third-Party Cookies

Our Platform may include cookies from third parties, including:

• Google Analytics (analytics and performance tracking)
• Social media platforms (sharing buttons and embedded content)
• Advertising networks (personalized ads)
• Payment processors (secure transaction processing)

These third parties have their own privacy policies governing their use of cookies.

7.4 Other Tracking Technologies

We may also use:

• Web beacons (pixels): Small graphic images that track email opens and website visits
• Local storage: Browser-based storage for larger amounts of data
• Session storage: Temporary storage that expires when you close your browser
• Device fingerprinting: Techniques to identify devices based on configuration

7.5 Managing Cookies and Tracking

Browser Settings:

You can control cookies through your browser settings:

• Google Chrome: Settings > Privacy and security > Cookies and other site data
• Safari: Preferences > Privacy > Cookies and website data
• Firefox: Settings > Privacy & Security > Cookies and Site Data
• Microsoft Edge: Settings > Privacy, search, and services > Cookies

Cookie Consent Management:

When you first visit our Platform, we will request your consent for non-essential cookies. You can update your cookie preferences at any time through our cookie settings banner or in your account settings.

Opt-Out Links:

• Google Analytics: https://tools.google.com/dlpage/gaoptout
• Network Advertising Initiative: http://www.networkadvertising.org/choices/

Note: Blocking or deleting cookies may affect your ability to use certain features of the Platform.

8. Data Storage, Retention, and Security

8.1 Data Storage Location

Your personal data is primarily stored on secure servers located in Nigeria and/or in data centers operated by reputable international cloud service providers with servers in regions that provide adequate data protection.

We ensure that all data storage complies with Nigerian data protection requirements.

8.2 Data Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by Nigerian law.

Active Accounts:

• Personal data is retained while your account is active

Closed Accounts:

• Most personal data is deleted within 90 days of account closure
• Some data may be retained longer for legal, regulatory, or legitimate business purposes

Transaction Records:

• Financial and transaction data is retained for at least 6 years to comply with Nigerian tax and accounting laws

Legal Claims:

• Data necessary for legal claims is retained until the matter is resolved

Marketing Data:

• Marketing-related data is retained until you withdraw consent or request deletion

Analytics Data:

• Anonymized analytics data may be retained indefinitely

You can request deletion of your data at any time by contacting us (see Section 10 for data subject rights).

8.3 Data Security Measures

We implement comprehensive technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

Technical Safeguards:

• Encryption of data in transit (SSL/TLS protocols)
• Encryption of data at rest
• Secure authentication mechanisms (password hashing, two-factor authentication)
• Regular security audits and vulnerability assessments
• Firewalls and intrusion detection systems
• Secure software development practices
• Regular security updates and patches

Organizational Safeguards:

• Access controls and role-based permissions (only authorized personnel can access data)
• Employee training on data protection and security
• Confidentiality agreements with employees and contractors
• Data breach response and incident management procedures
• Regular backups and disaster recovery plans
• Third-party security certifications and compliance

Payment Security:

• Payment data is processed by PCI-DSS compliant payment processors
• We do not store complete payment card details
• Secure payment gateways with encryption and tokenization

8.4 Data Breach Notification

In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach (as required by NDPA 2023)
• Notify affected users without undue delay
• Provide information about the nature of the breach, potential consequences, and remedial measures
• Take immediate steps to contain and remedy the breach

8.5 Limitations

While we implement strong security measures, no system is completely secure. We cannot guarantee absolute security of your data transmitted over the internet. You are responsible for maintaining the confidentiality of your account credentials.

9. Cross-Border Data Transfers

9.1 International Transfers

Some of our service providers and partners may be located outside Nigeria. When we transfer your personal data to countries outside Nigeria, we ensure that:

• The receiving country provides an adequate level of data protection as determined by the Nigeria Data Protection Commission (NDPC)
• Appropriate safeguards are in place, such as:
  • Standard contractual clauses approved by the NDPC
  • Binding corporate rules
  • Adequacy decisions recognizing equivalent protection
  • Your explicit consent for the transfer

9.2 Safeguards for International Transfers

We require all international service providers to:

• Implement appropriate technical and organizational security measures
• Process data only in accordance with our instructions
• Comply with applicable data protection laws
• Notify us immediately of any data breaches
• Allow audits and inspections of their data processing activities

9.3 Your Rights Regarding International Transfers

You have the right to:

• Request information about international data transfers
• Object to transfers that do not meet adequate protection standards
• Request that your data be processed only within Nigeria (subject to operational limitations)

10. Your Data Protection Rights

Under the Nigeria Data Protection Act (NDPA) 2023, you have the following rights regarding your personal data:

10.1 Right of Access

You have the right to request:

• Confirmation of whether we process your personal data
• Access to your personal data
• Information about how your data is processed, including purposes, categories, recipients, and retention periods
• A copy of your personal data in a commonly used format

10.2 Right to Rectification (Correction)

You have the right to:

• Request correction of inaccurate or incomplete personal data
• Update your account information at any time through your account settings

10.3 Right to Erasure (Deletion / "Right to Be Forgotten")

You have the right to request deletion of your personal data when:

• The data is no longer necessary for the purposes it was collected
• You withdraw consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed
• Deletion is required to comply with a legal obligation

Exceptions: We may retain certain data when required by law, for legal claims, or for legitimate business purposes.

10.4 Right to Restriction of Processing

You have the right to request that we restrict processing of your personal data when:

• You contest the accuracy of the data (during verification)
• Processing is unlawful but you prefer restriction over deletion
• We no longer need the data but you need it for legal claims
• You have objected to processing (pending verification of our legitimate grounds)

10.5 Right to Data Portability

You have the right to:

• Receive your personal data in a structured, commonly used, machine-readable format
• Transmit your data to another service provider where technically feasible
• Request direct transfer of your data to another controller

This right applies to data you provided based on consent or contract performance.

10.6 Right to Object

You have the right to object to:

• Processing based on legitimate interests (we will stop unless we demonstrate compelling legitimate grounds)
• Direct marketing (we will stop immediately upon request)
• Automated decision-making and profiling

10.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

10.8 Right to Lodge a Complaint

If you believe we have violated your data protection rights, you have the right to lodge a complaint with:

Nigeria Data Protection Commission (NDPC)
Website: https://ndpc.gov.ng/
Email: info@ndpc.gov.ng
Address: [NDPC Official Address]

You may also have the right to seek judicial remedy in Nigerian courts.

10.9 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: privacy@nigeriacreators.com.ng
Data Protection Officer: dpo@nigeriacreators.com.ng
Subject Line: "Data Subject Rights Request"

Please include:

• Your full name and registered email address
• Clear description of the right you wish to exercise
• Specific details about your request
• Proof of identity (to prevent unauthorized access)

Response Timeline:

We will respond to your request within 30 days of receiving a valid request. In complex cases, we may extend this period by an additional 30 days and will inform you of the delay.

Verification:

To protect your privacy, we may request additional information to verify your identity before processing your request.

No Fee:

Exercising your data protection rights is generally free of charge. We may charge a reasonable fee for repetitive, excessive, or manifestly unfounded requests.

11. Children's Privacy

11.1 Age Restriction

NigeriaCreators is not intended for children under the age of 18. We do not knowingly collect, use, or disclose personal data from individuals under 18 years of age.

11.2 Parental Consent

If you are under 18, you may only use our Platform with the involvement, consent, and supervision of a parent or legal guardian who agrees to be bound by our Terms of Service and this Privacy Policy.

11.3 Discovery of Children's Data

If we become aware that we have inadvertently collected personal data from a child under 18 without proper parental consent, we will:

• Delete the data as soon as possible
• Terminate the associated account
• Take steps to prevent future unauthorized access

11.4 Reporting

If you believe we have collected data from a child under 18, please contact us immediately at privacy@nigeriacreators.com.ng so we can take appropriate action.

12. Automated Decision-Making and Profiling

12.1 Use of Automated Processing

We may use automated processing and profiling for purposes such as:

• Fraud detection and prevention
• Personalized content recommendations
• Targeted advertising
• Risk assessment
• Customer segmentation

12.2 Your Rights

You have the right to:

• Not be subject to decisions based solely on automated processing that produce legal effects or significantly affect you
• Request human intervention in automated decisions
• Express your point of view
• Contest automated decisions

12.3 Transparency

When we use automated decision-making that significantly affects you, we will:

• Inform you of the processing
• Explain the logic involved
• Describe the significance and consequences
• Provide information about your rights

13. Third-Party Links and Services

Our Platform may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to third-party sites.

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party sites you visit.

When you use third-party services integrated with our Platform (such as social media login or payment processors), you are subject to their privacy policies and terms.

14. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in our data processing practices
• New legal or regulatory requirements
• Improvements to our services
• Feedback from users or regulators

14.1 Notification of Changes

When we make material changes to this Privacy Policy, we will:

• Update the "Last Updated" date at the top of this page
• Notify you via email (to the address associated with your account)
• Display a prominent notice on our Platform
• Request your consent for material changes where required by law

14.2 Your Continued Use

Your continued use of NigeriaCreators after we publish or notify you of changes to this Privacy Policy constitutes your acceptance of the updated policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

15. Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including:

• Nigeria Data Protection Act (NDPA) 2023
• Nigeria Data Protection Regulation (NDPR) 2019 (to the extent still applicable)
• Other relevant Nigerian data protection and privacy laws

Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Nigeria.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

General Privacy Inquiries:
Email: privacy@nigeriacreators.com.ng

Data Protection Officer:
Email: dpo@nigeriacreators.com.ng

Customer Support:
Email: support@nigeriacreators.com.ng

Mailing Address:
NigeriaCreators
[Insert Physical Address in Nigeria]

Website:
https://www.nigeriacreators.com.ng/

We will respond to your inquiries within a reasonable timeframe, typically within 30 days.

17. Additional Information for Nigerian Data Subjects

17.1 Compliance with NDPA 2023

NigeriaCreators is committed to full compliance with the Nigeria Data Protection Act (NDPA) 2023 and regulations issued by the Nigeria Data Protection Commission (NDPC).

17.2 Data Protection Impact Assessments

Where required by law, we conduct Data Protection Impact Assessments (DPIAs) for processing activities that pose high risks to your rights and freedoms.

17.3 Data Protection Registration

We maintain appropriate registration with the Nigeria Data Protection Commission as required by Nigerian law.

17.4 Your Right to Compensation

Under the NDPA 2023, you have the right to compensation for material or non-material damage resulting from our violation of data protection laws.