Privacy Policy

1. Introduction

IGETAM DIGITAL COMMERCE LTD ("we," "us," "our," or "the Platform") is committed to protecting the privacy of our users ("you" or "your"). This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in compliance with the Nigeria Data Protection Regulation (NDPR) 2019 and other applicable Nigerian data protection laws.

2. Data Controller

IGETAM DIGITAL COMMERCE LTD is the data controller responsible for your personal data. Our contact details are provided in Section 14.

3. Personal Data We Collect

3.1 Information You Provide

When you register, create listings, or use our Platform, we collect:

• Identity Data: Full name, business/hustle name
• Contact Data: Email address, phone number, WhatsApp number
• Location Data: State, city, shop address (optional)
• Profile Data: Profile photo, bio, business description
• Listing Data: Product/service descriptions, images, prices, categories
• Payment Data: Payment confirmation for access fee (via third-party payment processor - we do NOT store card details)
• Verification Data: Identification documents (if submitted for verification badge)

3.2 Information We Collect Automatically

When you use the Platform, we automatically collect:

• Technical Data: IP address, browser type, device type, operating system
• Usage Data: Pages visited, time spent, click patterns, search queries
• Location Data: General geographic location based on IP address
• Cookie Data: Information collected via cookies and similar technologies

3.3 Information from Third Parties

We may receive data from:

• Payment processors (Paystack) confirming successful payment
• Analytics providers (Google Analytics)
• Social media platforms (if you link your account)

4. How We Use Your Personal Data

4.1 Platform Operations

• Creating and managing user accounts
• Displaying seller storefronts and product listings
• Facilitating contact between buyers and sellers
• Processing access fee payments
• Verifying seller accounts (optional verification badge)
• Enforcing Terms of Use and preventing fraud
• Providing customer support

4.2 Communication

• Sending account activation and confirmation emails
• Notifying users of important Platform updates
• Responding to inquiries and support requests
• Sending security alerts and policy updates

4.3 Analytics and Improvement

• Analyzing Platform usage patterns and trends
• Improving Platform functionality and user experience
• Conducting research and development
• Monitoring Platform performance and security

4.4 Marketing (With Consent)

• Sending promotional emails and newsletters (you may opt out anytime)
• Displaying relevant product recommendations
• Informing users of new features or services

5. Legal Basis for Processing (NDPR Compliance)

We process your personal data based on:

• Contract Performance: Processing necessary to provide Platform services
• Legal Obligation: Compliance with Nigerian laws and regulations
• Legitimate Interests: Platform security, fraud prevention, business analytics
• Consent: Marketing communications (you may withdraw consent anytime)

6. Data Sharing and Disclosure

6.1 Public Display

6.2 Third-Party Service Providers

We share data with trusted service providers who assist in Platform operations:

• Payment Processors: Paystack (for access fee payment processing)
• Cloud Hosting: Vercel, Supabase (for Platform infrastructure)
• Image Hosting: Cloudinary (for product and profile images)
• Analytics: Google Analytics (for usage statistics)
• Email Services: Resend (for transactional emails)

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

6.3 Legal Requirements

We may disclose your personal data if required by:

• Court orders, subpoenas, or legal processes
• Nigerian law enforcement or regulatory authorities
• Legal obligations under Nigerian law
• Protection of our rights, property, or safety

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to continued privacy protection.

6.5 No Sale of Data

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (HTTPS/SSL)
• Secure cloud infrastructure with access controls
• Regular security audits and vulnerability assessments
• Employee training on data protection practices
• Two-factor authentication for sensitive accounts

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

8. Cookies and Tracking Technologies

8.1 What Are Cookies?

Cookies are small text files stored on your device when you visit the Platform. We use cookies to:

• Remember your login session
• Analyze Platform usage and traffic patterns
• Improve user experience and personalization
• Serve relevant advertisements (if applicable)

8.2 Types of Cookies We Use

• Essential Cookies: Necessary for Platform functionality (cannot be disabled)
• Analytics Cookies: Google Analytics to understand user behavior
• Functional Cookies: Remember your preferences and settings
• Advertising Cookies: (If applicable) Track ad performance

8.3 Cookie Management

You can control cookies through your browser settings. Note that disabling essential cookies may impair Platform functionality.

9. Data Retention

We retain your personal data for as long as:

• Your account remains active
• Necessary to provide Platform services
• Required by Nigerian law (e.g., financial records for 6 years)
• Necessary to resolve disputes or enforce agreements

After deletion, we may retain anonymized or aggregated data for analytics purposes.

10. Your Rights Under NDPR

As a data subject in Nigeria, you have the right to:

10.1 Access

Request a copy of the personal data we hold about you.

10.2 Rectification

Request correction of inaccurate or incomplete data.

10.3 Erasure ("Right to Be Forgotten")

Request deletion of your personal data, subject to legal obligations.

10.4 Objection

Object to processing of your data for direct marketing or legitimate interests.

10.5 Data Portability

Request your data in a structured, machine-readable format.

10.6 Withdrawal of Consent

Withdraw consent for marketing communications or optional data processing.

10.7 Complaint to Authority

Lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your rights have been violated.

11. Children's Privacy

The Platform is NOT intended for users under 18 years of age. We do not knowingly collect data from minors. If we become aware of such collection, we will promptly delete the data.

12. International Data Transfers

Your data is primarily stored on servers located within Nigeria or cloud infrastructure with Nigerian data residency options. If data is transferred internationally, we ensure appropriate safeguards are in place as required by NDPR.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or Platform notice. Continued use of the Platform after changes constitutes acceptance.

14. Contact Us

For privacy-related inquiries, data protection concerns, or to exercise your NDPR rights, contact: