Privacy Policy

This Privacy Policy explains how goBUDDY Technologies Ltd. ("goBUDDY," "we," "us," or "our") collects, uses, stores, shares, transfers, and protects the personal data of website visitors, users, vendors, and other individuals who interact with our services ("Data Subjects"). These services include our website, mobile and web applications, APIs, software platforms, customer support channels, email communications, and other digital products, tools, and services operated by goBUDDY.

This Privacy Policy also outlines your rights regarding the processing of your personal data and the choices available to you in relation to how your information is collected, used, and managed, regardless of the manner in which you access or engage with our services.

1. Who We Are

goBUDDY is a software development company offering mobile and web applications, APIs, websites, cloud-based solutions, software maintenance and support services, and related IT services. For the purposes of the Nigeria Data Protection Act ("NDPA"), we act as the Data Controller in respect of personal data collected through our Website, marketing channels, business communications, and customer relationship management activities. We may also act as a Data Processor where we process personal data solely on behalf of our clients pursuant to written contracts and service agreements. In such cases, the client remains the Data Controller and determines the purposes and means of processing.

At goBUDDY, safeguarding the privacy and security of our consumers' and users' personal data is a top priority. We are dedicated to maintaining transparency, accountability, and confidentiality in how we handle and protect your data.

This Privacy Policy applies to all systems, operations, and processes within the goBUDDY ecosystem that involve the processing of personal data. It does not extend to services, websites, or applications that are not owned, operated, or controlled by goBUDDY, including those of third parties.

We are committed to handling personal data in compliance with the purposes and processing methods set out in this Privacy Policy and in accordance with the principles and requirements prescribed by the Nigeria Data Protection Act, 2023, and the General Application and Implementation Directive ("GAID").

2. Personal Data We Collect

In the course of our business operations and the provision of our services, goBUDDY may collect and process personal data relating to Data Subjects. The types of personal data we collect depend on the nature of your interaction with us and may include:

• Personal identification information such as your name, date of birth, gender, photograph, and government-issued identification details;
• Contact information, including your email address, telephone number, residential or business address, and other contact details you provide;
• Account information, such as login credentials, account preferences, profile information, and records relating to your use of our services;
• Transaction and payment information, including payment details, billing information, transaction records, and purchase history;
• Device and technical information, such as IP address, browser type, operating system, device identifiers, application logs, and information relating to your access to and use of our platforms;
• Location information, where required to provide our services or where you have enabled location-based features;
• Communications data, including information contained in enquiries, complaints, feedback, customer support interactions, emails, and other correspondence with us;
• Vendor and business information, including company details, regulatory documentation, bank account information, tax information, and other records required for onboarding and managing business relationships.

We may also collect personal data automatically through cookies and similar technologies when you access or use our website, mobile application, or other digital channels. Further information regarding our use of cookies is provided in our Cookie Policy.

Where you choose not to provide certain personal data, we may be unable to provide some or all of our services or fulfil our contractual and legal obligations to you.

3. How We Collect Personal Data

• We collect personal data through our interactions with you and through your use of our products and services. In most cases, personal data is collected directly from you when you create an account, complete forms, make enquiries, request services, contact our customer support team, participate in surveys or promotions, or otherwise communicate with us.
• We also collect certain information automatically when you access or use our website, mobile applications, and other digital platforms. This may include technical information about your device, browsing activities, usage patterns, and other information collected through cookies and similar technologies.
• In some circumstances, we may obtain personal data from third parties, including business partners, payment service providers, identity verification vendors, service providers, marketing partners, publicly available sources, and regulatory or governmental authorities where permitted or required by law.
• Where you interact with goBUDDY on behalf of an organisation, we may collect personal data during the course of establishing or managing our relationship with that organisation, including during onboarding, contractual engagements, compliance checks, and ongoing business operations.
• We may also collect personal data through social media platforms and other third-party channels where you engage with our content, communicate with us, or permit such information to be shared with us.
• From time to time, we may combine personal data obtained from different sources to maintain accurate records, improve our services, enhance security, prevent fraud, comply with legal and regulatory obligations, and provide a better user experience.

All personal data is collected and processed in accordance with applicable data protection laws and only for legitimate, specified, and lawful purposes.

4. Legal Basis and Purposes of Processing

We process personal data only where there is a lawful basis for doing so under the NDPA and GAID. Depending on the nature of the processing activity, we may rely on:

• Consent, where you have freely provided your consent for a specific purpose;
• Contractual necessity, where processing is required to provide our services or fulfil our contractual obligations to you;
• Legal obligation, where processing is necessary to comply with applicable laws, regulations, or lawful requests from public authorities;
• Legitimate interests, where processing is necessary for our legitimate business interests, provided that such interests do not override your fundamental rights and freedoms; and
• Any other lawful basis permitted under applicable data protection laws.

We may process your personal data for the following purposes:

• To create, manage, and administer your account;
• To provide, operate, and maintain our products and services;
• To process transactions and facilitate payments;
• To verify identity and conduct security, fraud prevention, and risk management activities;
• To communicate with you regarding your account, transactions, enquiries, and customer support requests;
• To improve, develop, and enhance our products, services, and user experience;
• To conduct analytics, system monitoring, and performance assessments;
• To send updates, promotional materials, and marketing communications where permitted by law or with your consent;
• To manage our relationships with vendors, partners, and service providers; and
• To comply with legal, regulatory, contractual, and internal governance requirements.

We will not process your personal data for purposes that are incompatible with those for which it was collected unless permitted or required by law.

5. Sharing and Disclosure of Personal Data

We may share your personal data with trusted third parties where necessary to provide our services, operate our business, comply with legal obligations, or protect our legitimate interests.

Your personal data may be shared with:

• Service providers and technology partners who support the delivery of our products and services;
• Payment service providers, hosting providers, cloud service providers, and other vendors engaged by us;
• Professional advisers, including legal, audit, and consulting firms;
• Regulatory authorities, government agencies, law enforcement bodies, and courts where required by law; and
• Business partners, clients, or contractors where disclosure is necessary for the performance of our services.

We require all third parties that process personal data on our behalf to maintain appropriate security measures and to process such data only in accordance with our instructions and applicable law.

We do not sell or rent personal data to third parties. We may also disclose personal data where necessary to establish, exercise, or defend legal claims, protect our rights, investigate fraud or security incidents, or comply with applicable legal and regulatory requirements.

6. Data Retention

goBUDDY retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including the provision of our products and services, compliance with legal and regulatory obligations, dispute resolution, enforcement of contractual rights, and the protection of our legitimate business interests.

The period for which we retain personal data depends on the nature of the information, the purpose for which it is processed, and any applicable legal, regulatory, contractual, or operational requirements. In general, we may retain personal data:

• For as long as your account remains active or as required to provide our services;
• For the duration of our contractual relationship with you;
• For as long as necessary to comply with applicable legal, regulatory, tax, accounting, or reporting obligations;
• For the period required to investigate, prevent, or detect fraud, security incidents, or other unlawful activities;
• For as long as necessary to establish, exercise, or defend legal claims; and
• For such additional periods as may be required or permitted under applicable law.

Where personal data is no longer required for the purpose for which it was collected, we will take reasonable steps to securely delete, destroy, anonymize, or pseudonymize such data in accordance with our retention practices and applicable legal requirements.

Notwithstanding the foregoing, we may retain anonymized or aggregated data that no longer identifies any individual for research, analytics, service improvement, statistical, and business intelligence purposes.

7. Data Security

goBUDDY implements appropriate technical, organizational, and administrative measures designed to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

These measures include, where appropriate, the use of access controls, data encryption, firewalls, secure systems, and other security technologies aimed at safeguarding the confidentiality, integrity, and availability of personal data. Access to personal data is restricted to authorized personnel and service providers who require such access for legitimate business purposes and are subject to confidentiality obligations.

While we take reasonable steps to protect personal data, no method of electronic transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security but will continue to review and enhance our security measures in line with industry standards and evolving threats.

We remain committed to maintaining the confidentiality, integrity, and security of personal data and to processing such information in a manner that preserves the trust and confidence of our users, customers, and business partners.

8. Your Rights as a Data Subject

goBUDDY respects your privacy rights and is committed to ensuring that you can exercise those rights in accordance with applicable data protection laws.

Subject to applicable legal and regulatory requirements, you may exercise the following rights in relation to your personal data:

• Right to Access: You have the right to request access to the personal data we hold about you and to obtain a copy of such information.
• Right to be Informed: You have the right to receive clear and transparent information about how we collect, use, store, disclose, and otherwise process your personal data.
• Right to Rectification: You may request that we correct, update, or complete any personal data that is inaccurate, incomplete, or outdated.
• Right to Erasure: You may request the deletion of your personal data where there is no lawful basis for its continued processing, subject to any legal or regulatory obligations requiring its retention.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
• Right to Object: You have the right to object to the processing of your personal data in certain circumstances, including processing for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Restrict Processing: You may request that we limit the processing of your personal data in specific circumstances permitted by law.
• Right to Data Portability: Where applicable, you may request that your personal data be provided to you or transferred to another service provider in a structured, commonly used, and machine-readable format.
• Rights Relating to Automated Decision-Making: You have the right to object to decisions based solely on automated processing where such decisions produce legal or similarly significant effects on you.
• Right to Lodge a Complaint: If you believe that your personal data has been processed in a manner that violates applicable data protection laws, you have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) or any other competent regulatory authority.

To exercise any of these rights, please contact our Data Protection Officer through the contact details provided in this Privacy Policy. We may request sufficient information to verify your identity before processing your request.

We will review and respond to all legitimate requests within the timeframe prescribed by applicable law. Where we are unable to comply with a request, we will provide the reasons for our decision, subject to any legal restrictions.

9. Children's Privacy

Our Website and services are intended for individuals who are at least 18 years of age. We do not knowingly collect, use, or process the personal data of individuals under the age of 18 except where such processing is permitted by applicable law and the required consent has been obtained from a parent or legal guardian.

If we become aware that we have collected personal data relating to a child without the necessary parental or guardian consent, we will take reasonable steps to promptly delete or otherwise cease processing such information in accordance with applicable legal requirements.

Parents or guardians who believe that a child has provided personal data to us without their consent may contact us using the details provided in this Privacy Policy.

10. Third-Party Links

The Website may contain links to third-party websites or services that are not owned or controlled by goBUDDY.

We are not responsible for the privacy practices, policies, or content of such third-party platforms. Users are encouraged to review the privacy policies of those platforms before providing any personal data.

11. Changes to This Privacy Policy

We may review and update this Privacy Policy from time to time to reflect changes in our business operations, services, technologies, or applicable legal and regulatory requirements. Where any material changes are made to the manner in which we collect, use, disclose, or otherwise process your personal data, we will take appropriate steps to notify you and, where required by law, obtain your consent before such changes take effect.

The most current version of this Privacy Policy will always be available through our official platforms and will take effect from the effective date indicated therein. Continued use of our services following any updates constitutes acknowledgment of the revised Privacy Policy, to the extent permitted by law.

12. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

goBUDDY Technologies Ltd.

Email: info@gobuddy-technologies.com

Address: [Insert Company Address]

Data Protection Officer: [Insert DPO Contact Details]