PRIVACY POLICY FOR FEEGOR DOTCOM LIMITED

• Interpretation and Definitions 

  • Interpretation

    Words with capitalised initials have meanings defined under the following conditions. These definitions shall have the same meaning whether they appear in singular or plural form.

  • Definitions

    For the purposes of this Policy:

    “Account” means a unique account created by a User to access, manage, and utilise features of the Service, including placing or receiving orders, managing transactions, and interacting with other Users on the Platform

    “Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with Feegor, including subsidiaries, holding companies, or joint venture partners. 

    “Buyer” means any User who registers on the Platform to browse, request, negotiate, and purchase goods in bulk from Vendors.

    “Company”, “Feegor”, “We”, “Us”, or “Our” refers to Feegor Dotcom Limited, including its employees, representatives, and authorised agents.

    “Commission” means the Nigeria Data Protection Commission, the regulatory authority responsible for the administration and enforcement of data protection laws in Nigeria. 

    “Country” means the Federal Republic of Nigeria. 

    “Device” means any device capable of accessing the Service, including but not limited to computers, mobile phones, tablets, or other internet-enabled devices. 

    “Identity Verification Data” means personal identification information such as National Identification Number (NIN), Bank Verification Number (BVN), or government-issued identification submitted for verification purposes.

    “Invoice” means a document generated by a Vendor or Feegor (on behalf of a Vendor) detailing the goods, pricing, and terms of a Transaction.

    “Logistics Partner” means third-party logistics providers engaged by Vendors or Feegor to facilitate the storage, handling, and delivery of goods to Buyers. Such providers may act as data processors in respect of any personal data they handle, and shall at all times remain independent contractors, not agents or representatives of Fegoor.

    “Personal Data” means any information relating to an identified or identifiable natural person, as defined under the Data Protection Laws. 

    “Service” means the platforms, products, websites, applications, and related services provided by Feegor including any tools, features, payment solutions, or other offerings made available through its digital infrastructure. 

    “Service Provider” means any natural or legal person that processes Personal Data on behalf of the Company, including vendors providing hosting, analytics, messaging, payment processing, identity verification, customer support, or logistics services.

    “Transaction Data” means data generated in connection with activities carried out on the Service, including payment records, invoice details, order information, and payout-related information.

    “Transaction” means any interaction between Users on the Platform relating to the request, negotiation, purchase, sale, invoicing, payment, or delivery of goods.

    “Usage Data” means data collected automatically through the use of the Service or from the Service infrastructure itself, including but not limited to IP address, browser type, device identifiers, pages visited, and timestamps. 

    “Vendor” means any supplier, manufacturer, or business User who lists products, responds to order requests, issues invoices, and fulfils orders through the Platform.

    “Wallet” means a digital account feature (where applicable) that facilitates payments, settlements, or transaction tracking on the Platform, which may be supported by licensed third-party financial service providers.

    “You” or “User” means any individual or entity accessing or using the Service, including Buyers and Vendors.

    The above definitions shall have the same meaning regardless of whether they appear in singular or plural.

• Information Collection and Use

  • Types of Data Collected

    Depending on how you use the Platform, we may collect and process different categories of Personal Data as outlined below:

    • Registered Users (Buyers and Vendors)

      When you create an Account, register as a Buyer or Vendor, set up a store, send or receive order requests, negotiate transactions, or make purchases on the Platform, we may collect the following categories of Personal Data that you voluntarily provide:

      • Full name;
      • Email address;
      • Mobile phone number and WhatsApp number;
      • Username and password credentials (stored in a secure, encrypted format);
      • Business information (including business name, type, and description);
      • Location information (including city, state, LGA, and business or delivery address);
      • Product and store information (for Vendors), including product listings, pricing, descriptions, and images;
      • Communication data, including messages, negotiation records, and interactions with other Users or Feegor support;
      • Order and request data, including order requests sent or received, order preferences, and saved items;
      • Invoice-related information generated in connection with Transactions;
      • Bank account details provided for payouts (for Vendors);
      • Any other information you choose to provide when using the Platform.

      By completing the registration process, you consent to the collection, storage, and use of your Personal Data in accordance with this Policy.

    • Identity Verification Data

      Where required for wallet functionality, payouts, regulatory compliance, or fraud prevention, we may facilitate the collection of identity verification data, including:

      • National Identification Number (NIN);
      • Bank Verification Number (BVN);
      • Government-issued identification (e.g., driver’s licence, international passport, voter’s card);
      • Biometric verification data for identity matching

      Feegor does not store sensitive identity verification data such as NIN, BVN, or biometric data. Such data is securely transmitted via APIs to licensed third-party verification providers solely for authentication and compliance purposes.

    • Unregistered Users (Passive Data Collection)

      If you access or browse the Platform without creating an account, we may still collect certain information automatically through passive means (“Passive Data Collection”), including:

      • Cookies and similar tracking technologies (see our Cookies Policy);
      • Internet Protocol (IP) address;
      • Browser type, version, and device information;
      • Date, time, and duration of visit;
      • General location data and referring web pages.

      This information helps us to secure, maintain, and improve the performance of our Services.

    • Transactional Data

      When you engage in Transactions on the Platform (including order requests, invoicing, payments, and fulfilment), we may collect and process:

      • Order details and transaction records;
      • Invoice data;
      • Payment confirmations and transaction references;
      • Payout information for Vendors;
      • Delivery and fulfilment information, including logistics and dispatch details.

      We process this data to facilitate transactions, enable order fulfilment, provide customer support, and maintain accurate records.

    • Related Entities and Affiliates

      We may share your Personal Data with other affiliated entities within the Feegor ecosystem, provided they adhere to equivalent data protection and security standards as set out in this Policy.

    • Marketing Communication

      In line with your consent, we may collect and use your name, phone number, WhatsApp number and email address to send updates, promotions and marketing. You may opt out of receiving marketing communications at any time by following the unsubscribe instructions in such communications or reach us via our email [*].

    • Service Communications

      For the purpose of rendering our services we will collect and use your name, phone number, WhatsApp number and email address to send updates on orders and delivery, and our other service-related notifications.

    • Communications and Support Data

      When you interact with Feegor support or communicate with Vendors or Buyers through the Platform, we may collect:

      • Customer support inquiries and complaint records;
      • Chat messages, call logs, and interaction history;
      • Feedback, reviews, and survey responses.

      This enables us to facilitate negotiations, resolve disputes, and improve service delivery.

    • Usage Data

      We automatically collect technical and analytical data (“Usage Data”) whenever you use our Platform. Usage Data may include:

      • Device identifiers and operating system;
      • IP address and approximate location;
      • App version, session duration, and navigation behaviour;
      • Diagnostic and performance logs.

      This information supports system performance analysis, fraud prevention, and service optimisation.

    • Automated Decision-Making and Profiling

      In the course of providing the Platform and related services, Feegor may utilise automated processing, including profiling, to enhance user experience, improve service delivery, and support transaction efficiency.

      Such processing may include:

      • recommending Vendors, products, or services based on user activity, preferences, location, and transaction history;
      • prioritising or ranking product listings and search results;
      • detecting and preventing fraudulent or suspicious transactions; and
      • enabling automated responses through chatbots or customer support tools.

      These activities are carried out using algorithms and system-based analysis of Personal Data to facilitate faster and more relevant interactions on the Platform.

      Where automated decision-making produces legal or similarly significant effects on Users, Feegor shall ensure that appropriate safeguards are implemented, including the possibility of human intervention, where required under applicable law.

    • Data Storage and International Transfers

      Feegor stores and processes Personal Data using secure cloud-based infrastructure and other technology systems designed to ensure the confidentiality, integrity, and availability of such data.

      Personal Data collected through the Platform may be stored on servers hosted by third-party service providers, including cloud hosting providers that may be engaged by Feegor from time to time.

      Depending on the configuration of these services, Personal Data may be transferred to and stored in jurisdictions outside Nigeria. Where such cross-border transfers occur, Feegor shall ensure that:

      • the destination country provides an adequate level of data protection; or
      • appropriate safeguards are implemented in accordance with applicable data protection laws, including contractual protections and data transfer mechanisms.

      Feegor shall take all reasonable steps to ensure that Personal Data is handled securely and in accordance with this Privacy Policy, regardless of where it is processed.

  • How We Handle Your Personal Data

    The Personal Data you provide to us is:

    • processed fairly, lawfully, and in a transparent manner;
    • collected for a specific purpose and is not processed in a way that is incompatible with the purpose for which Feegor collected it;
    • adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;
    • kept accurate, secure, and, where necessary, kept up to date
    • kept no longer than is necessary for the purposes for which the Personal Information is processed;
    • processed in accordance with the Data Protection Laws.

    Please note that we or any of our Affiliates shall not sell your Personal Data, and we also will not permit the selling of customer data by any company that provides a service to us, as our service providers are bound by confidentiality agreements and are obligated to process data in accordance with the Data Protection Laws.

  • Purposes of Processing of Personal Data

    The Company may collect and use Personal Data for the following lawful and legitimate purposes, in accordance with the Data Protection Laws:

    • We process Personal Data where necessary to perform our contract with you or to take steps at your request prior to entering a contract.

    • We may use your Personal Data to:

      • contact you via email, SMS, phone calls, or other electronic means regarding service updates, account issues, and operational notices;
      • notify you about new features, service improvements, or system maintenance;
      • respond to your inquiries, feedback, complaints, or support requests;
    • Subject to your consent, we may use your Personal Data to send you promotional messages, offers, or information about products or services similar to those you have used or enquired about. You have the right to withdraw your consent to marketing communications at any time by using the unsubscribe option or contacting us directly via our email address.

    • We process Personal Data where required by law, regulation, or governmental authority, including to:

      • Comply with obligations under the tax laws, or transport and logistics regulations;
      • Respond to lawful requests or investigations by the Nigeria Data Protection Commission (NDPC), the Economic and Financial Crimes Commission (EFCC), the Nigerian Financial Intelligence Unit (NFIU), or other competent authorities;
      • Detect, prevent, and investigate fraud, money laundering, or other unlawful activities;
      • Enforce our Terms of Use and protect our rights and interests in legal proceedings.

    • We may process Personal Data as necessary to:

      • Conduct internal business audits, risk assessments, and service quality evaluations;
      • Manage business continuity and disaster recovery;
      • Evaluate or execute business transfers, mergers, acquisitions, or restructuring involving the Company, where Personal Data forms part of the transferred assets;
      • Store data securely using reputable cloud storage solutions within or outside Nigeria, ensuring compliance with data transfer safeguards under Section 41 of the NDPA.
    • We may process your Personal Data to establish, exercise, or defend our legal rights in the event of a dispute, prevent misuse, unauthorised access, or breach of our systems, address and resolve user complaints or data subject requests.

  • Circumstances Where We May Share Your Personal Data

    We may share or disclose your Personal Data with third parties only where it is lawful, necessary, and consistent with the purposes described in this Policy. In all cases, we ensure that such third parties are subject to appropriate confidentiality and data protection obligations.

    • We may share your Personal Data with trusted third-party service providers who assist us in operating our Platform and delivering our Services. These service providers may include cloud hosting and data storage. They include providers, customer support and communications platforms , identity verification and compliance providers, as well as logistics and delivery partners engaged in fulfilling orders placed through the Platform. These parties act as data processors and are required to process Personal Data strictly in accordance with our instructions and under appropriate contractual safeguards.
    • We may share relevant Personal Data between Users to facilitate transactions on the Platform. This may include sharing Buyers’ contact details, order requests, and delivery information with Vendors, as well as making Vendors’ business information, store details, and product listings available to Buyers. In addition, transaction-related information, including invoices, negotiation records, and fulfilment updates, may be shared between the relevant parties where necessary to enable order processing, negotiation, invoicing, and delivery of goods.
    • If we are involved in a merger, acquisition, restructuring, financing, or sale of assets, your Personal Data may be transferred as part of that transaction. We will ensure that any recipient of such data agrees to respect your privacy in a manner consistent with this Policy.
    • Where required for verification, compliance, or fraud prevention purposes, we may share relevant Personal Data with licensed identity verification and compliance partners. For clarity, sensitive identification data such as National Identification Number (NIN), Bank Verification Number (BVN), or biometric data is not stored by Feegor but is transmitted securely to such partners solely for authentication and regulatory compliance purposes.
    • We may also share your Personal Data with trusted business or marketing partners in order to offer joint products, services, or promotions that may be of interest to you. Such sharing will only take place in line with your existing consent to this privacy policy or where otherwise permitted under applicable data protection laws.
    • We may disclose Personal Data where required to do so by law or in response to valid requests by public authorities. Such disclosure may include cooperation in investigations, enforcement of legal rights, or compliance with reporting obligations under applicable laws.
    • If you engage in public forums, reviews, feedback sections, or similar interactive areas on our Platform, any information you share may be visible to other users and may be publicly distributed beyond the Platform. You should exercise caution before sharing Personal Data in public areas.
    • Where Personal Data is transferred to a recipient located outside Nigeria, such transfer shall be carried out in compliance with Sections 41–44 of the Nigeria Data Protection Act 2023. We will ensure that adequate safeguards such as standard contractual clauses, adequacy decisions, or your explicit consent are in place to protect your Personal Data.
    • We may share your Personal Data for any other purpose not covered above, provided that we have obtained your explicit consent in accordance with the NDPA.
    • To facilitate the marketplace, we may disclose a Buyer’s delivery address and some personal information to the relevant Vendor and their designated Logistics Partner once a Transaction is initiated. Vendors are strictly prohibited from using this data for marketing purposes outside of the Feegor Platform without the Buyer’s separate consent.

  • Methods of Collection of Personal Data

    As a Data Controller, we collect Personal Data through lawful and transparent means, and only to the extent necessary for the purposes described in this Policy. If you consent to this privacy policy, you have accepted any of the provisions stated below;

    • When you interact with us directly, including through registration on the Platform, account creation, or when you provide information to access our services.
    • Through enquiry, registration, claim, feedback, and contact forms submitted on our Website or application.
    • When you use features of the Platform related to transactions, fulfilment, or delivery, we may collect relevant Personal Data as you submit order requests, provide delivery details, request quotations, or interact with Vendors, Feegor support, or logistics partners in connection with your orders.
    • When you fill out surveys, participate in feedback sessions, or comment on content or user-generated sections of our Website.
    • When you request service quotations, fill out delivery requests, or complete online application forms relating to our services.
    • Through cookies and similar technologies that collect information about your browsing activity and preferences. Details are available in our Cookies Policy.
    • Through telephone calls, which may be recorded for quality assurance, training, and dispute resolution purposes.
    • Through our customer engagement tools such as live chat, automated chatbots, and profiling features used to provide quick assistance and service recommendations.
    • From reputable third parties such as marketing agencies, analytics providers, or companies that supply consumer segmentation or classification data to help us tailor our offerings (subject to your consent or other lawful basis). Such third-party data helps us verify your identity, prevent fraud, improve our Services, and tailor our offerings to your needs, provided that such collection is conducted lawfully and, where required, based on your consent or another lawful basis.

• Lawful Basis for Data Processing

  We process personal data only when a lawful basis exists under the Data Protection Laws. Depending on the context, processing may rely on one or more of the following legal bases:

  • Consent – where you have freely given, specific, informed, and unambiguous consent.
  • Contractual necessity – where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
  • Legal obligation – where processing is necessary to comply with a legal duty or regulatory requirement.
  • Vital interests – where processing is required to protect your life or physical safety.
  • Legitimate interests – where we have a genuine and lawful interest that does not override your rights and freedoms (e.g., fraud prevention, product improvement).
  • For sensitive personal data, processing is generally based on explicit consent, unless a lawful exception applies.

• Third Parties:

  • From time to time, we engage trusted Service Providers to support the operation of our Platform, Website, and related services. These service providers may process Personal Data on our behalf, strictly in accordance with our instructions and this Privacy Policy.

    We may engage service providers to:

    • Host and maintain our Website, application, and related infrastructure;
    • Provide cloud-based information storage and backup services;
    • Facilitate order processing, payment collection, logistics coordination, and delivery fulfilment through Vendors or third-party logistics partners;
    • Analyse Platform usage, performance, and engagement, including page requests, session durations, navigation patterns, and referral sources, to improve service experience;
    • Provide customer support and engagement tools, including live chat, automated chatbots, and feedback platforms, to assist Users and Vendors during transactions and inquiries; and
    • Offer marketing, analytics, or communication services on our behalf.

  • We only share your Personal Data with Service Providers who have agreed to comply with our data protection standards and the Data Protection Laws. Each service provider is required to:

    • Use the data solely for the agreed purpose;
    • Implement adequate technical and organisational measures to secure the data; and
    • Refrain from selling or transferring Personal Data to unauthorised parties.
  • If we intend to share your Personal Data in a manner not described in this Policy, you will receive prior notice and have the option to opt out of such sharing.
  • In line with clause 4.3 may also request that we do not share your Personal Data with such third parties not contemplated under this agreement, although this may affect your ability to access certain services that depend on such third-party integrations. Requests of this nature may be sent to contact@feegor.com or any other contact address provided under this Policy.

• Privacy of Children

  Our Website and Services are not directed at children under the age of 18, and we do not knowingly collect, use, or disclose Personal Data from individuals within this age group. If you are a parent or legal guardian and believe that your child has provided us with Personal Data without your consent, please contact us immediately at contact@feegor.com so that we can take appropriate steps to delete such information from our records.

  Where we become aware that we have inadvertently collected Personal Data from a child under the age of 18 without verifiable parental consent, we will promptly delete such data and, where feasible, notify the parent or guardian.

  If we rely on consent as a lawful basis for processing Personal Data and the applicable law requires parental or guardian consent for minors, we will obtain such consent before collecting or using that Personal Data.

• Retention of Your Personal Data

  The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. For users who register on our Website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except that they cannot change their username). Website administrators can also see and edit that information.

  The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Website, or we are legally obligated to retain this data for longer periods.

• Your Rights Regarding Your Data

  You can ask us to do various things with your Personal Data. For example, at any time, you can ask us for a copy of your Personal Data, ask us to correct mistakes, change the way we use your information, or even delete it. We will either do what you have asked or explain why we cannot - usually because of a legal or regulatory issue.

  You have the following rights in relation to our use of your Personal Data as guaranteed under the Data Protection Laws.

  • The right to rectification

    We take reasonable steps to ensure that the Personal Data we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us by using the details below, and you can ask us to update or amend it.

  • The right to object

    You have the right to object to the processing of Personal Data relating to you. In such an instance, we shall discontinue the processing of your Personal Data. However, we may choose to continue processing Personal Data for public interest or other grounds, which overrides your rights, interests, and freedom.

  • The right to erasure

    In certain circumstances, you have the right to ask us to erase your Personal Data, for example, where the Personal Data we collected is no longer necessary for the original purpose or where you withdraw your consent. However, this will need to be balanced against other factors, for example, according to the type of Personal Data we hold about you and why we have collected it, there may be some legal and regulatory obligations that preclude us from complying with your request.

  • Right to restriction of processing

    In certain circumstances, you are entitled to ask us to stop using your Personal Data, for example, where you think that the Personal Data we hold about you may be inaccurate or where you think that we no longer need to process your Personal Data.

  • Right to data portability

    In certain circumstances, you have the right to ask that we transfer any Personal Data that you have provided to us to another third party of your choice. Once transferred, the other party will be responsible for your Personal Data.

  • The right to withdraw consent

    For certain uses of your Personal Data, we will ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your Personal Data. Please note that in some cases, we may not be able to process your Services request if you withdraw your consent.

  • The right to lodge a complaint with the Commission

    Where you are aggrieved by any of our decisions, actions, or inactions, you reserve the right to lodge a complaint with the Commission in accordance with the regulations/mechanisms specified by the Commission from time to time.

• Modification and Access to Personal Data

  To the extent required by Data Protection Laws, you may be able to request that we inform you about the Personal Data we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your Personal Data. We will respond to your access requests within a reasonable time and make all required updates and changes within the time specified by the Data Protection Laws.

  When permitted by the Data Protection Laws, we may charge an appropriate fee to cover the costs of responding to the request. Where the timeline specified in the Data Protection Laws cannot be met, we will communicate same to you and take steps to notify you where we require an extension.

• Opting Out of Transmittals from Us:

  From time to time, we may send you information or marketing, such as announcements or other information. If you wish to opt out of such marketing communications, you may contact the following email: contact@feegor.com  You may also click the opt-out link which will be provided at the bottom of any and all such marketing communications. 

  You may opt out of service communication if you wish to opt out. Please be advised that even though you may opt out of such service communications, you may still receive information from us that is specifically about your use of our platforms or about your account with us. 

• Breach/ Privacy Violation

  In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information which is likely to result in a risk to the rights and freedom of the Data Subjects (as defined under the Data Protection Laws), Feegor shall within 72 (seventy-two) hours of knowing about such breach, report the details of the breach including describing the nature of the personal data breach, the categories and approximate numbers of data subjects and personal data records concerned to the Commission.

  Furthermore, we shall within 7 (seven) days of knowing the occurrence of such breach, take steps to inform the Data Subject of the breach incident, the risk to the rights and freedoms of the Data Subject resulting from such breach and any course of action to remedy said breach.

• Changes to this Policy

  We reserve the right to modify, revise, or otherwise amend this Policy at any time and in any manner. We will notify you of any changes by posting the new Policy on our Platform. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective.

  You are advised to review this Policy periodically for any changes. Please note that changes to this Policy are effective when they are posted on this Website.

• Our Contact Information

  If you have any questions about this Privacy Policy or the way we collect information from you, or if you would like to launch a complaint about anything related to this Privacy Policy, you may contact us at the following email address: contact@feegor.com