Privacy Policy for NaijaCP

1. Introduction

Welcome to NaijaCP ("we," "our," "us"). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our mobile application and website (collectively, the "Services").

This policy applies to all users of NaijaCP, regardless of location. If you are located in the European Union (EU) or European Economic Area (EEA), additional rights and protections apply to you under the General Data Protection Regulation (GDPR).

Controller Information:

2. Information We Collect

2.1 Information You Provide Directly

We collect information that you voluntarily provide when you:

• Create an account or register for our Services
• Make purchases or transactions
• Contact our customer support
• Subscribe to newsletters or promotional communications
• Participate in surveys or feedback requests

This information may include:

• Contact Information: Name, email address, phone number
• Account Information: Username, password (encrypted), profile preferences
• Payment Information: Payment card details, billing address (processed through secure third-party payment processors)
• Communication Data: Messages, feedback, and correspondence with us

2.2 Information Collected Automatically

When you use our Services, we automatically collect:

• Device Information: Device type, operating system, unique device identifiers, mobile network information
• Usage Data: App features accessed, time spent on features, interaction patterns, crash reports
• Log Data: IP address, browser type, access times, pages viewed, referring URLs
• Location Data: Approximate location based on IP address (we do not collect precise GPS location unless you grant permission)
• Cookies and Tracking Technologies: See Section 8 for details

2.3 Information from Third Parties

We may receive information from:

• Social Media Platforms: If you connect your social media accounts to our Services
• Payment Processors: Transaction confirmation and payment status
• Analytics Providers: Aggregated usage statistics and app performance data
• Advertising Partners: Ad interaction data (if applicable)

3. Legal Basis for Processing (GDPR)

For users in the EU/EEA, we process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary to provide our Services to you (Article 6(1)(b) GDPR)
• Legitimate Interests: Improving our Services, fraud prevention, security, and business operations (Article 6(1)(f) GDPR)
• Legal Obligation: Compliance with applicable laws, tax regulations, and legal requests (Article 6(1)(c) GDPR)
• Consent: Marketing communications, cookies, and optional features (Article 6(1)(a) GDPR) - You may withdraw consent at any time

4. How We Use Your Information

4.1 Service Provision

• Create and manage your account
• Process transactions and deliver purchased products/services
• Provide customer support and respond to inquiries
• Send transactional notifications (order confirmations, account updates)

4.2 Service Improvement

• Analyze usage patterns to improve app functionality
• Conduct research and development for new features
• Monitor and improve app performance and security
• Fix bugs and technical issues

4.3 Communication

• Send important service announcements and updates
• Respond to your questions and requests
• Provide customer support

4.4 Marketing (With Your Consent)

• Send promotional emails about new features, products, or offers
• Personalize content and recommendations
• Conduct surveys and request feedback

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

4.5 Legal and Security

• Comply with legal obligations and regulations
• Prevent fraud, abuse, and unauthorized access
• Enforce our Terms of Service
• Protect the rights and safety of our users and the public

5. How We Share Your Information

We do not sell your personal data. We may share your information in the following circumstances:

5.1 Service Providers

We share data with trusted third-party service providers who assist us in:

• Payment processing (e.g., Stripe, Paystack, Flutterwave)
• Cloud hosting and data storage
• Analytics and app performance monitoring
• Customer support tools
• Email delivery services

These providers are contractually obligated to protect your data and use it only for specified purposes.

5.2 Legal Requirements

We may disclose your information when required by law or in response to:

• Court orders, subpoenas, or legal processes
• Requests from government authorities or law enforcement
• Protection of our legal rights and property
• Investigation of fraud or security issues
• Emergency situations involving danger to persons or property

5.3 Business Transfers

If NaijaCP is involved in a merger, acquisition, sale of assets, or bankruptcy, your personal data may be transferred to the successor entity. We will notify you of any such change and your choices regarding your data.

5.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

5.5 Aggregated Data

We may share anonymized, aggregated statistical data that cannot identify you individually for business purposes, research, or marketing.

6. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this Privacy Policy:

• Account Data: Retained while your account is active, plus 90 days after account deletion (to handle disputes or comply with legal obligations)
• Transaction Records: Retained for 7 years to comply with tax and accounting regulations
• Marketing Data: Retained until you unsubscribe or withdraw consent, plus 30 days
• Usage Logs: Typically retained for 12-24 months for security and analytics purposes
• Support Communications: Retained for 3 years after resolution

After the retention period, we securely delete or anonymize your personal data.

7. Your Rights and Choices

7.1 Rights for All Users

You have the right to:

• Access: Request information about the personal data we hold about you
• Update: Correct inaccurate or incomplete information through your account settings
• Delete: Request deletion of your account and associated data
• Opt-Out: Unsubscribe from marketing emails at any time

7.2 Additional Rights for EU/EEA Users (GDPR)

Under GDPR, you also have the right to:

• Data Portability: Receive your personal data in a structured, machine-readable format (Article 20)
• Restrict Processing: Request limitation of how we process your data in certain circumstances (Article 18)
• Object: Object to processing based on legitimate interests or for direct marketing purposes (Article 21)
• Withdraw Consent: Where processing is based on consent, withdraw it at any time (Article 7(3))
• Lodge a Complaint: File a complaint with your local data protection authority if you believe your rights have been violated

7.3 How to Exercise Your Rights

To exercise any of these rights, contact us at:

We will respond to your request within 30 days (or as required by applicable law). We may need to verify your identity before processing certain requests.

8. Cookies and Tracking Technologies

8.1 What We Use

We use cookies, web beacons, and similar technologies to:

• Remember your preferences and settings
• Analyze how you use our Services
• Improve app performance and user experience
• Deliver relevant content and advertisements (if applicable)

8.2 Types of Cookies

• Essential Cookies: Necessary for the app to function (cannot be disabled)
• Performance Cookies: Help us understand how users interact with our Services
• Functional Cookies: Remember your preferences and personalize your experience
• Marketing Cookies: Track your activity for advertising purposes (with your consent)

8.3 Your Cookie Choices

You can manage cookie preferences through:

• Your device settings
• Your browser settings
• Our in-app cookie consent manager (if available)

Note: Disabling certain cookies may affect app functionality.

9. Data Security

We implement industry-standard security measures to protect your personal data, including:

• Encryption: Data transmitted over secure HTTPS/TLS connections
• Access Controls: Restricted access to personal data on a need-to-know basis
• Regular Audits: Periodic security assessments and vulnerability testing
• Secure Storage: Data stored on secure servers with encryption at rest
• Employee Training: Staff trained on data protection and security practices

However, no method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

You are responsible for: Keeping your account password secure and notifying us immediately of any unauthorized access.

10. International Data Transfers

NaijaCP operates from Nigeria. If you are located outside Nigeria (including in the EU/EEA), your personal data may be transferred to, stored, and processed in Nigeria or other countries where our service providers operate.

For EU/EEA users: When we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by the European Commission
• Other legally recognized transfer mechanisms

11. Children's Privacy

Our Services are not intended for children under the age of 13 (or 16 in the EU/EEA). We do not knowingly collect personal data from children.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at feedback@naijacp.com. We will take steps to delete such information from our systems.

12. Third-Party Links and Services

Our Services may contain links to third-party websites, apps, or services that are not operated by us. We are not responsible for the privacy practices of these third parties.

We encourage you to review the privacy policies of any third-party services you access through our platform.

Third-party services we may integrate with include:

• Payment processors
• Social media platforms
• Analytics providers
• Advertising networks

13. Changes to This Privacy Policy

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

• Our business practices
• Legal or regulatory requirements
• Technology and security standards

When we make changes:

• We will update the "Last Updated" date at the top of this policy
• For material changes, we will notify you via email or in-app notification
• We encourage you to review this policy periodically

Your continued use of our Services after changes constitutes acceptance of the updated Privacy Policy.

14. Contact Us

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

For EU/EEA users: If you are not satisfied with our response, you have the right to lodge a complaint with your local supervisory authority.

15. Data Protection Officer (If Applicable)

Currently, NaijaCP does not have a dedicated Data Protection Officer. All privacy-related inquiries should be directed to the contact information above.

Your privacy matters to us. Thank you for trusting NaijaCP with your personal information.