1. Introduction

Welcome to Saudat Data, operated by SAUDAT ONLINE PLAZA LIMITED (Company Registration No. 7894668). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

We are committed to protecting your privacy and ensuring the security of your personal information. As a VTU (Virtual Top-Up) service provider, we collect certain information necessary to deliver our services efficiently.

2. Information We Collect

To provide you with our VTU services, we collect the following types of information:

2.1 Personal Information You Provide

• Account Information: Name, email address, phone number, and profile information
• Transaction Information: Payment details, transaction history, and purchase records
• Verification Information: Government ID, BVN, or NIN for KYC compliance (where required)
• Communication Data: Messages, support requests, and feedback you send us

2.2 Information Automatically Collected

• Device Information: Device model, operating system, unique device identifiers
• Usage Data: App interactions, features used, time spent, and navigation paths
• Location Information: Approximate location based on IP address (with your consent)
• Log Data: IP address, browser type, access times, and crash reports

2.3 Information for VTU Services

• Recipient Information: Phone numbers for airtime/data purchases
• Smartcard Numbers: For cable TV subscriptions (DSTV, GOtv, Startimes)
• Meter Numbers: For electricity bill payments
• Exam Registration Numbers: For exam pin purchases

3. How We Use Your Information

Your information helps us provide, maintain, and improve our services. Specifically, we use your data for:

• Service Delivery: Process VTU transactions, airtime purchases, data subscriptions, and bill payments
• Account Management: Create and manage your user account, verify identity, and prevent fraud
• Customer Support: Respond to your inquiries, resolve issues, and provide technical support
• Transaction Records: Maintain accurate records of your purchases and wallet transactions
• Service Improvement: Analyze usage patterns to enhance app functionality and user experience
• Legal Compliance: Comply with regulatory requirements, including anti-fraud and KYC regulations
• Communication: Send important updates, transaction confirmations, and promotional offers (with opt-out option)
• Security: Detect and prevent fraudulent activities, unauthorized access, and security incidents

4. Information Sharing & Disclosure

We respect your privacy and do not sell your personal information. However, we may share your information in the following circumstances:

4.1 Service Providers

We share information with trusted third-party partners who assist in:

• Payment processing and fraud detection
• Telecommunication networks for VTU services
• Cloud hosting and data storage
• Customer support and analytics services

4.2 Legal Requirements

We may disclose your information if required by law, court order, or government regulation, including:

• Complying with legal processes or law enforcement requests
• Protecting our rights, property, or safety
• Investigating and preventing fraud or security issues

4.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your information may be transferred. We will notify you of any such change.

4.4 With Your Consent

We may share your information for other purposes with your explicit consent.

5. Data Security

We implement robust security measures to protect your information:

• Encryption: All sensitive data is encrypted using SSL/TLS technology during transmission
• Access Controls: Strict access controls and authentication protocols for data access
• Secure Storage: Data stored on secure servers with firewalls and intrusion detection systems
• Regular Audits: Periodic security assessments and vulnerability testing
• Transaction PIN: Optional PIN protection for wallet transactions
• Session Management: Automatic logout after periods of inactivity

While we strive to protect your data, no method of transmission over the internet is 100% secure. We encourage you to:

• Use strong, unique passwords for your account
• Never share your login credentials or transaction PIN
• Log out after each session, especially on shared devices
• Report any suspicious activity immediately

6. Your Rights & Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of your personal data we hold
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your account and personal data
• Restriction: Limit how we process your information
• Portability: Receive your data in a machine-readable format
• Opt-out: Unsubscribe from marketing communications
• Withdraw Consent: Withdraw previously given consent for data processing

How to Exercise Your Rights

To exercise any of these rights, contact us at support@saudatdata.com.ng or use the in-app support feature. We will respond within 30 days.

7. Children's Privacy

Our services are intended for users aged 18 and above. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us immediately, and we will delete such information.

For users between 13-18, we require parental consent before using our VTU services.

8. Third-Party Services

Our app may contain links to third-party websites or services. This Privacy Policy does not apply to those services. We encourage you to review the privacy policies of any third-party services you use.

Third-party services we may integrate:

• Payment gateways (Paystack, Flutterwave, etc.)
• Telecom providers (MTN, Glo, Airtel, 9mobile)
• Analytics services (Google Analytics, Firebase)
• Cloud storage providers

9. Data Retention

We retain your personal information for as long as necessary to:

• Provide our VTU services to you
• Comply with legal and regulatory requirements (typically 5-7 years for financial transactions)
• Resolve disputes and enforce agreements
• Improve our services and develop new features

If you close your account, we will delete or anonymize your personal information within 90 days, except where retention is required by law.

10. Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. When we make material changes, we will:

• Notify you via in-app notification or email
• Update the "Last Updated" date at the top of this policy
• Require your acknowledgment of significant changes

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

11. Contact Information

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

For Data Privacy Complaints

If you are unsatisfied with our response, you may lodge a complaint with the Nigeria Data Protection Commission (NDPC) or your local data protection authority.

Response Time

We aim to respond to all privacy-related inquiries within 5-7 business days.