Privacy & Data Protection Policy

DRAFT — pending DPO appointment and NDPR/NDPB registration. This placeholder must be replaced with a standalone, NDPR-compliant Data Protection Policy before launch.

1. Data We Collect

Identity data (full name, date of birth, government ID for KYC Tiers 2 & 3), contact data (email, phone), financial data (wallet transactions, deposit/withdrawal records), and usage data (predictions, community activity, chat messages).

2. Legal Basis & Purpose

Data is processed to provide the Service, comply with NLRC/AML/KYC obligations, prevent fraud, and communicate with users about their account, predictions, and settlements.

3. Third-Party Processors

MongoDB (database and uploaded files), Flutterwave and Paystack (payments), Resend (email notifications), and football data feed providers. A Third-Party AI Disclosure (fraud detection, AI Community name generation) is pending finalisation.

4. Your Rights

Under the NDPR, you may request access, correction, or deletion of your personal data, subject to our regulatory retention obligations (e.g. AML transaction records).

5. Data Protection Officer

[OPEN — DPO appointment pending.]