Controller and scope
Glemad MS Limited is the data controller for Nabtap users in Nigeria. Its place of business and postal contact is Plot 15 Orchid Road, Lekki, Lagos, Nigeria. Public privacy enquiries may be sent to [email protected]; verified rights requests should use the Nabtap Contact Centre.
This Notice applies with the global Privacy Policy. If Nigerian law gives you a stronger right, that right continues to apply.
Notice is not consent
The Privacy Policy and this Notice explain processing. They are not account agreements and do not obtain blanket consent. Nabtap may record that a notice was presented or acknowledged, but that record is not consent to optional processing.
Where consent is the lawful basis, the request must identify the specific processing and offer an affirmative choice. Refusing or withdrawing optional consent does not remove access to the core service. A feature that cannot work without the information you chose to provide may remain unavailable.
Purposes, information and lawful bases
- Create and authenticate an account; publish, deliver and store requested content, messages and settings. This uses account, content, activity and device information and is necessary to perform the Terms.
- Protect accounts, detect fraud and abuse, enforce rules and respond to safety reports. This uses account, content, activity, device and report information for legal duties and legitimate interests in safety and service integrity.
- Process purchases, payouts, identity checks, tax and accounting. This uses transaction, business, tax and verification information for contract and legal obligations, with consent where Nigerian law requires it for a particular check.
- Rank feeds and recommend content. This uses follows, interests, activity, content and device signals to perform the service and for legitimate interests in relevance, subject to your controls and our assessment of your rights.
- Personalize advertising, send direct marketing, use optional partner activity, sync contacts or use precise location where offered. This uses the information named in the request and relies on consent where Nigerian law requires consent.
- Measure, diagnose, research and improve Nabtap. This uses device, activity, diagnostic and survey information for legitimate interests, or consent where required.
- Respond to valid legal process and establish, exercise or defend claims. This uses the information relevant to the request or claim for legal obligations, public interest or legitimate interests.
Recipients
Information may be disclosed to the audience you select; contracted providers for hosting, content delivery, security, analytics, support, identity checks, communications and payments; Glemad affiliates that help operate Nabtap; a partner you ask us to connect; professional advisers and transaction counterparties; and authorities or rights holders where disclosure has a valid legal basis.
We limit a recipient to information needed for its role and require contractual protection where the recipient processes information for us. A recipient acting as its own controller must provide its own notice where required.
Advertising choices
The personalized ads setting controls whether activity on Nabtap is used to choose advertisements. Activity supplied by partners has a separate setting and is off by default. Turning personalization off does not remove advertisements, but future selection must not use the covered personalization signals.
Nabtap does not use private-message content or identity-document images for advertising and does not profile a person it knows with reasonable certainty is under 18 for advertising. You may object at any time to direct marketing, including related profiling.
Automated processing and consequences
- Recommendation profiling affects the order and discovery of content. It does not by itself produce a legal or similarly significant effect. Following, feedback, reset controls and the chronological feed can change the result.
- Advertising profiling affects which advertisement may be shown. Advertising personalization can be turned off without removing access to the core service.
- Safety, fraud and enforcement systems may prioritize a report, protect an account, limit distribution or identify suspected violations. A qualifying decision can be challenged, and safeguards include human intervention, the opportunity to explain your position and an appeal where available.
People under 18
Nabtap’s minimum account age is 18. We do not offer a parent-consent route for a child to create an account. A person under 18 is not eligible for advertising profiling, contact discovery, precise-location recommendations or other optional account processing.
If we learn that an account holder is under 18, we may restrict the account while we verify the report and then close the account and delete the information. We may retain only what a specific law, safety need or legal claim requires, and only for as long as that reason applies.
Retention
- Account, profile and settings information: while the account is active, followed by the stated 30-day deletion recovery period and the deletion process, subject to required records.
- Deleted content and media: removed from active product systems and queued for deletion, subject to protected backup rotation and a specific legal or safety hold.
- Temporary data-export files: seven days.
- Raw identity documents: no more than 90 days while a request is open and scheduled for deletion within seven days after a decision.
- Transactions, tax, consent, security, enforcement and legal records: the applicable statutory period or the period reasonably needed for fraud prevention, disputes and legal claims.
International transfers
Information may be transferred from Nigeria to the United States and other countries where a Glemad affiliate or contracted provider performs the services described above. We record the destination and legal basis for each transfer in the internal processing record.
A transfer must rely on adequate protection through applicable law, binding corporate rules, contractual clauses, an approved code or certification mechanism, or another condition permitted by the Nigeria Data Protection Act. You may ask for information about the safeguard that applies to your information.
Your rights and complaints
- Ask whether Nabtap processes your information and obtain access to it and information about its use, source, recipients, retention and automated processing.
- Correct inaccurate, incomplete, out-of-date or misleading information.
- Request deletion or restriction, and object to processing, subject to lawful exceptions.
- Withdraw consent as easily as it was given. Withdrawal applies to future processing and does not undo processing that was lawful before withdrawal.
- Challenge a qualifying solely automated decision and ask for human intervention.
- Lodge a complaint with the Nigeria Data Protection Commission if you believe your rights have been infringed.
Changes to this document
We may update this document to reflect changes to Nabtap, the law or the way we protect the community. When a change is material, we will provide notice appropriate to its significance and request fresh acceptance where required.
Contact
Questions, complaints and rights requests can be sent through the Nabtap Contact Centre. Public legal enquiries may be sent to [email protected]. Formal notices must use the method stated in the relevant transaction or an official company record.