PRIVACY POLICY

1. Who We Are (Data Controller)

Temzyola Tech Limited is the Data Controller for personal data processed in connection with our services. We are registered with the Corporate Affairs Commission (CAC) of the Federal Republic of Nigeria (incorporated May 10, 2024).

Data Protection Contact:
Email: hello@temzyolatech.com
WhatsApp: +234 901 236 6230
Telegram: @temzyolatech

2. What Data We Collect

2.1 Data You Provide

• Identity Data: Full name, username or similar identifiers.
• Contact Data: Phone number (including WhatsApp), email address, Telegram handle.
• Financial Data: Bank account details, payment references (for escrow transactions). We do not store card numbers.
• Transaction Data: Details of digital assets bought or sold, service type, transaction values, and correspondence related to deals.
• Business Data: Website URLs, Google Analytics access, AdSense account information, YouTube channel data — provided for verification and service delivery purposes.
• Marketing Data: Your preferences for receiving communications from us.

2.2 Data We Collect Automatically

• Website usage data (pages visited, time on site, device type, browser).
• IP address and general geolocation data.
• Communication metadata from WhatsApp and Telegram interactions (subject to those platforms' own privacy policies).

3. How We Collect Data

We collect personal data through:

• Direct interactions — when you contact us via WhatsApp, Telegram, email, or our website contact form.
• Service transactions — when you engage us to buy, sell, or access any of our services.
• Third-party platforms — such as Google (for ADX service), YouTube, and TikTok Business Manager, as required to deliver services.
• Website analytics tools, if applicable.

4. Why We Use Your Data (Legal Bases)

We process personal data on the following legal bases under the NDPA 2023 and GDPR:

• Contract Performance: To fulfil the services you have engaged us for — including facilitating transactions, ADX approvals, and ad management.
• Legitimate Interests: To prevent fraud, verify identities, improve our services, and maintain business records. We balance these interests against your privacy rights.
• Legal Obligation: To comply with Nigerian law, including tax obligations, EFCC requirements, and any lawful regulatory requests.
• Consent: Where you have given explicit consent, such as for receiving marketing communications. You may withdraw consent at any time.

5. How We Share Your Data

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

• Transaction counterparties: In brokered transactions, limited identity verification information may be shared between buyer and seller as necessary to complete the deal — with consent.
• Service providers: Trusted third-party service providers who assist us in delivering our services (e.g., payment processing), under strict data processing agreements.
• Legal authorities: Where required by Nigerian law, court order, or legitimate request from law enforcement or regulatory bodies (e.g., EFCC, FCCPC, CAC).
• Platform partners: Google and TikTok receive data as necessary to apply for ADX or set up ad campaigns — governed by their own privacy policies.

All third parties are required to respect the security of your personal data and to treat it in accordance with applicable law.

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Transaction records: Retained for a minimum of 6 years in accordance with Nigerian financial record-keeping requirements under CAMA 2020.
• Marketing data: Until you withdraw consent or request deletion.
• Service correspondence: For 2 years after service completion, for dispute resolution purposes.
• Website analytics data: Typically 26 months, in line with industry standards.

After these periods, data is securely deleted or anonymized.

7. International Data Transfers

As a Nigerian company operating globally and using platforms such as Google and TikTok, some of your data may be processed outside Nigeria. When this occurs:

• We ensure adequate safeguards are in place, including Standard Contractual Clauses (SCCs) for EU data subjects.
• We only transfer data to countries or organizations that provide an adequate level of protection consistent with the NDPA 2023 and GDPR requirements.
• You may request details of specific transfer mechanisms by contacting us.

8. Your Rights

Under the Nigeria Data Protection Act 2023, NDPR 2019, and GDPR (where applicable), you have the following rights:

To exercise any of these rights, contact us at: hello@temzyolatech.com or WhatsApp: +234 901 236 6230. We will respond within 30 days as required by law.

9. Cookies & Tracking

Our website may use cookies and similar tracking technologies to improve user experience and gather analytics. Types include:

• Essential cookies: Required for basic website functionality.
• Analytics cookies: Used to understand how visitors use our site (e.g., Google Analytics). These are anonymized.

You can control cookies through your browser settings. Disabling non-essential cookies will not affect your ability to use our services. Third-party platforms (WhatsApp, Telegram, TikTok) operate under their own cookie and tracking policies.

10. Children's Privacy

Our services are not intended for persons under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it promptly. If you believe a minor has provided us with personal data, please contact us immediately.

11. Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These include:

• Access controls limiting data access to authorized personnel only.
• Secure communication channels for sensitive information exchange.
• Regular review of our data handling practices.

While we take security seriously, no transmission over the internet or messaging platform is 100% secure. We encourage you to avoid sharing sensitive financial information (e.g., PINs, passwords) through any channel.

12. Third-Party Links

Our communications and website may contain links to third-party websites and services (e.g., Google, TikTok, YouTube). We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies independently.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. We will notify you of material changes by posting the updated policy on our website and, where appropriate, notifying you via WhatsApp or email with at least 7 days' notice before the changes take effect.

Continued use of our services after the effective date of any changes constitutes your acceptance of the updated Policy.

14. Contact & Complaints

For any privacy-related questions, requests to exercise your rights, or complaints:

• Email: hello@temzyolatech.com
• WhatsApp: +234 901 236 6230
• Telegram: @temzyolatech

If you are dissatisfied with our response, you have the right to lodge a complaint with:

• Nigeria: Nigeria Data Protection Commission (NDPC) — ndpc.gov.ng
• EU residents: Your national Data Protection Authority
• UK residents: Information Commissioner's Office (ICO) — ico.org.uk

This Privacy Policy was last reviewed and updated on January 1, 2025. Temzyola Tech Limited — Incorporated May 10, 2024, Federal Republic of Nigeria.