In this Privacy Policy, terms such as "we", "us, "our", or similar expressions shall mean SecretSwapp and Userspace Technologies Limited.

We take your privacy very seriously and are committed to protecting your personal data (meaning any information about you from which you can be identified).

This Privacy Policy explains what personal data we collect when you:

• Use our Services: access our website (regardless of where you visit it from), use our official app.
• engage with us (or we engage with your content) on social media platforms (including our Facebook, X, YouTube and Instagram pages);
• Otherwise engage, interact, or communicate with us.

Please read this Privacy Policy carefully:

1. Background
2. Your Consent
3. The Data we collect about you
4. How we collect your Data
5. How do we use your Data
6. Legal Basis for the Processing of Data
7. Transferring your Data
8. International Data Transfers
9. Security of your Data
10. Data Retention
11. Your Rights
12. Changes to this policy
13. Contact Us
14. Background

At SecretSwapp, we recognize the importance of safeguarding your privacy and are committed to handling your personal information with the utmost care and transparency. This Privacy Policy outlines our detailed practices regarding the collection, use, disclosure, and protection of your information.

We are a "controller" under the Nigerian Data Protection Act, 2023 and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the Data Protection Law, we will ensure that the personal data we hold about you is, at all times:

1. used fairly, lawfully, and transparently.
2. collected for limited, specific purposes only.
3. adequate, relevant to, and limited to what is necessary for those purposes.
4. kept accurate and up to date.
5. not kept for longer than is necessary; and
6. held securely.

We shall be accountable for and able to demonstrate our compliance with our obligations under the Data Protection Law, and this Privacy Policy is one of the ways in which we do that.

We have appointed a Data Protection Professional to oversee compliance with this Privacy Policy and our data protection compliance activities. The Data Protection Lead has also established a dedicated data protection team to provide the necessary support.

1. Your Consent

By using SecretSwapp, you acknowledge and agree to the collection, storage, use, and disclosure of your information as described in this Privacy Policy. Except as otherwise required by operation of law or principles of law, your consent as the data subject is paramount in our considerations. You have the right to give, withhold or otherwise withdraw your consent to data processing.

1. The Data we collect about you

We collect two primary types of information from our users: "Non-personal data" and "Personal data".

Non-Personal data: This refers to information that cannot be directly linked to your identity. It encompasses anonymous user data, IP addresses, aggregated demographic data (such as age and gender), referring/exit pages and URLs, types of devices used (e.g., desktop, mobile), user click activity, and personal preferences.

Personal data refers to any information that can be used to identify a specific individual directly or indirectly. We collect your personal data in order to provide tailored products and services and in order to analyse and continually improve our products and services. We may collect, use, store and transfer different kinds of personal data for marketing and personal data optimization purposes. We also use Google Digital Marketing to propose targeted offers for certain products and services.

You provide us with your personal data when you register your personal details on our website and mobile platforms and complete transactions using them.

The personal data we collect includes:

Information you provide to us: We receive and store the information you provide to us including your identity data, contact data, biometric data, delivery address and financial data. These types of personal data may include:

• Contact details (such as your name, postal addresses, phone numbers, and email addresses).
• Demographic information (such as your date of birth, age or age range, and gender).
• Online registration information (such as your password and other authentication information).
• Payment information (such as your credit or debit card information and billing address).
• information provided as part of online questionnaires (such as responses to any customer satisfaction surveys or market research),
• Competition entries/submissions.
• In certain cases, your marketing preferences.

We strive to provide you with choices regarding the Personal Data that you provide to us. If you wish to have your Personal Data used by us to provide you with a personalized experience/targeted advertising & content, you can indicate so through the relevant tick- box(es) located on the registration form. If you decide that you no longer wish to benefit from this personalization, you can opt out or adjust your preferences at any time or by sending an email to hello@secretswapp.online.

1. How we collect your Data

You provide us with your personal data when you:

• Access, use or our Services.
• Create an account on our website.
• Request information, marketing, and other communications to be sent to you.
• Enter a competition, promotion, or survey.
• Complete surveys or provide us with your feedback.
• Register and/or attend any of our Events.
• Otherwise interact or correspond with us (including via email, social media, or telephone).

In connection with some elements of the Services, Projects, and Events, we also receive additional personal data about you from other organisations that have collected personal data from you.

We may also receive personal data as part of the legal processes we undertake to protect our Services and our intellectual property.

We collect the Technical Data automatically as you interact with our Services by using cookies and other similar web technologies. Please refer to our Cookie Policy for more information.

We also use third party tools to help us manage and analyse our social media presence, and report on comments, mentions, and other content that is posted about us on social media platforms and other public channels and forums. These third parties' activities, and their

information collection and sharing practices, are subject to the terms of the relevant social media platform, channel, or forum. We will use this information in accordance with this Privacy Policy.

We may also collect data through email tracking technologies, such as when you interact with our marketing communications. This includes tracking emails opened via pixel images and link clicks via redirect URLs.

We may collect your preferences and interests either explicitly—such as during onboarding when you choose preferences (which you may skip)—or infer them from your engagement with our Services, including browsing behaviour and content viewed. Inferred preferences are determined using cookies and similar technologies, subject to your consent choices. This helps us build a more personalised experience for you across our website, app, and marketing communications.

1. How do we use your Data

Enhancing Your Secret Swapp Experience: We use your information to provide you with the best possible SecretSwapp experience, enabling you to create a profile, participate in gift exchanges, and communicate with other users effectively.

Product and Service Improvement: We use your information to analyze usage patterns, gather user feedback, and continuously improve our products and services to better meet your needs.

We may also leverage artificial intelligence to gain insights into user behaviour.

When using artificial intelligence to analyze user behaviour, we strive to provide accurate insights. However, we cannot guarantee the completeness or accuracy of AI-generated content. Users are advised to verify information before making important decisions on our platform. We take reasonable steps to protect user data and comply with applicable laws and regulations.

Marketing Communications: We use your information to send you relevant marketing communications, such as newsletters and promotional offers, but only if you have explicitly opted in to receive them.

Legal and Regulatory Compliance: We use your information to fulfill our legal and regulatory obligations, ensuring adherence to applicable laws and regulations.

We use your personal data to operate, provide, develop and improve the products and services that we offer, including the following:

• Registering you as a new user.
• Processing and delivering your orders.
• Managing your relationship with us.
• Enabling you to participate in promotions, competitions and surveys.
  
• Improving our website, applications, products and services.
• Recommending/advertising products or services which may be of interest to you.
• Enabling you to access certain products and services offered by our partners and vendors.
• Complying with our legal obligations, including verifying your identity where necessary.
• Detect fraud.

1. Legal Basis for the Processing of Data

We process your personal data only when we have a valid legal basis to do so. The legal basis depends on the purpose of collection and use. Typically, our legal basis falls into one of the following categories:

• Consent: We process your data when you've given consent, such as for marketing purposes. You can withdraw consent at any time, including by using the "unsubscribe" link in marketing emails.
• Legitimate Business Interests: We process data to understand our customers, promote services, and operate effectively, while ensuring your privacy and rights are respected.
• Contract Performance: We process data to fulfill contracts with you, such as processing orders and sending products.
• Compliance with Law: We may process data to comply with legal obligations.

1. Transferring your Data

We may share your information with the following third parties:

Service Providers: We may share your information with trusted service providers who assist us in operating SecretSwapp and delivering services to you, such as but not limited to website hosting providers and email service providers.

Marketing Partners: We may share your information with carefully selected marketing partners who assist us in promoting our products and services to you, but only if you have opted to receive marketing communications.

Law Enforcement and Government Officials: We may disclose your information to law enforcement agencies and government officials when legally required or to protect our rights or property.

1. International Data Transfers

We may transfer your personal data to countries outside your location, where permissible by applicable laws. Such transfers carry inherent risks. To mitigate these risks, we implement measures to protect your data and maintain the same level of protection as in the country of origin. We continue to respect your legal rights under this Privacy Notice and applicable laws in your location.

1. Security of your Data

We have implemented robust security measures to protect your personal data from:

• Unauthorized access, use, or disclosure.
• Accidental loss or alteration.

We limit access to your data to authorized personnel, including employees, agents, contractors, and third parties, who:

• Have a legitimate business need to know.
• Process data only on our instructions.
• Are bound by confidentiality obligations.

In the event of a suspected data breach, we have procedures in place to respond promptly and notify you and relevant regulators as required by law.

1. Data Retention

We will process your personal data for the minimum period necessary to achieve the purposes outlined in this Privacy Policy. Your data will be retained only for as long as:

• We have an ongoing relationship with you, enhancing your experience and ensuring relevant communications.
• It's necessary for the purposes outlined, on a valid legal basis.
• There's a potential legal claim against us, within applicable limitation periods.

We regularly review the data we hold and:

• Delete it securely when there's no longer a need.
• Anonymize it when possible, to minimize retention.

1. Your Rights

Keeping Your Data Accurate

It's essential that your personal data is accurate and up to date. Please inform us if your data changes during your relationship with us.

Your Data Protection Rights

You have certain rights under data protection laws, including:

• Accessing, correcting, or erasing your personal data.
• Objecting to or restricting processing.
• Requesting data transfer to a third party.
• Unsubscribing from emails and newsletters.
  

Deleting Your Data

To permanently delete your data and discontinue your relationship with us, you can:

• Contact our customer service team.
• Close your account using the Delete Account feature.
• You have the right to access, correct, or delete your Personal Information. To do so, please contact us at hello@secretswapp.online.

Note that closing your account will terminate access to associated products and services. We may retain some data for legal and legitimate business purposes.

Exceptions to Your Requests

We may refuse unreasonable requests or those lacking necessary identity confirmation.

Filing a Complaint

You can lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you have concerns about our data handling practices.

1. Changes to this Policy

We may periodically update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of any material changes to this Policy by posting an updated version on our website and sending you an email notification.

1. Contact Us

If you have any questions or concerns about this Privacy Policy, please do not hesitate to contact us at hello@secretswapp.online .

Secret Swapp was made with love by the folks at Userspace Technologies.

We will thoroughly investigate complaints regarding our Personal Data management and respond to all substantiated complaints within prescribed timelines, ensuring timely resolution and adherence to regulatory requirements.