NaijaCupid Privacy Policy and Nigeria Data Protection Regulation (NDPR) Compliance

Your Privacy Matters: NaijaCupid Privacy Policy

Welcome to NaijaCupid, operated by LonerTech Ltd. We understand that trusting us with your personal information is a significant decision, particularly on a platform designed to help you form meaningful romantic connections. This Privacy Policy explains in clear terms exactly how we handle your data — with full transparency and no hidden surprises.

Your privacy is not merely a legal requirement for us — it is a core value. We are fully committed to NDPR compliance (Nigeria Data Protection Regulation) and to protecting every piece of information you share with us. This policy sets out what data we collect, why we need it, how we protect it, and — most importantly — the rights and control you have over your personal information.

1. What Information We Collect About You

To help you find meaningful connections on NaijaCupid, we collect certain personal data. Here is exactly what we gather and why:

Personal Information You Directly Provide:

• Profile Basics: Your name, email address, phone number (if provided), date of birth, gender, and general location (city/state — we never track your exact GPS coordinates without your explicit permission).
• Profile Content: The photos you upload, your bio description, interests, relationship preferences, and any other information you choose to share to help others get to know you.
• Communication Data: Messages you send and receive through our platform, as well as any feedback or reports you submit to our support team.
• Verification Information: If you choose to verify your account, we may collect additional identity confirmation details (processed securely and deleted after verification).

Sensitive Personal Data (Your Choice, Your Control):

• Optional Profile Details: Information such as sexual orientation, religious beliefs, ethnic background, or political views. You are NEVER required to provide this information. If you choose to include it on your profile, we process it only with your explicit consent and solely to help you find more compatible matches.
• Your Control: You can add, edit, or remove any sensitive data from your profile at any time through your account settings.

Financial Transaction Data:

• Payment Information: When you purchase premium features or subscriptions, our trusted payment processors (such as Paystack) handle your payment details directly. We do NOT store your full credit card numbers, CVV codes, or banking passwords on our servers. We retain only basic transaction records (date, amount, payment method type) for billing support and fraud prevention.

Technical and Usage Information (Collected Automatically):

• Device & Browser Data: Your IP address, device type, operating system, browser type and version, and unique device identifiers.
• Usage Analytics: How you use NaijaCupid — which features you interact with, session duration, search queries, profiles you view, and general navigation patterns. This helps us understand what is working and what needs improvement.
• Cookies & Similar Technologies: Small data files that remember your preferences and keep you logged in. See Section 5 for full details.
• Location Data: General location based on your IP address (city/state level). We access precise GPS location only if you explicitly grant permission through your device settings and only when using location-based features.

User-Generated Platform Activity:

• Interaction Logs: Likes, swipes, matches, profile views, and report submissions. These are retained to operate the platform, detect abuse, and protect the NaijaCupid community.
• Reported Content: If you report another user, we retain the details of that report (including any supporting content) for as long as necessary to investigate and enforce our platform rules, and in any case for a minimum of 12 months to protect against repeat offences.

2. Why We Need Your Data: Our Lawful Basis for Processing

Under the NDPR, we must have a valid legal reason to process your personal information. Here is why we collect and use your data:

To Provide the Service You Signed Up For (Contractual Necessity):

• Creating and managing your account
• Showing your profile to potential matches and theirs to you
• Enabling messaging and communication features
• Processing premium subscriptions and payments
• Providing customer support when you need help

Without this data, we cannot provide the dating service — it is essential to our contract with you.

To Protect the Platform and Its Users (Legitimate Interest):

• Security & Fraud Prevention: Monitoring for suspicious activity, detecting fake profiles, preventing scams, and protecting against cyber attacks and abuse.
• Enforcement of Terms of Service: Investigating reported violations, enforcing bans, and maintaining the integrity and safety of the NaijaCupid community. We reserve the right to use any data available to us to detect and prevent prohibited conduct.
• Platform Improvement: Analysing usage patterns to improve features and user experience.
• Business Protection: Maintaining records, protecting our intellectual property, and defending against fraudulent payment claims, chargebacks, or legal disputes brought in bad faith. Data relevant to such disputes may be retained indefinitely until all matters are resolved.
• Research & Analytics: Creating aggregated, anonymised statistics about platform usage for product development and business reporting.

With Your Explicit Consent (When You Say "Yes"):

• Processing sensitive profile data (e.g., religious beliefs, sexual orientation) to improve match compatibility
• Sending you marketing communications, dating tips, or special offers — only if you have opted in, and withdrawable at any time
• Using precise GPS location for location-based features — only if you grant device permission
• Non-essential cookies that personalise your experience

To Comply with Legal Obligations:

• Responding to valid legal requests from Nigerian law enforcement or courts
• Meeting NDPR reporting requirements and regulatory oversight
• Maintaining records for tax, accounting, and financial compliance
• Cooperating with regulatory investigations when legally required

3. How We Share Your Information (And With Whom)

We do not sell your personal data. However, in order to operate NaijaCupid effectively and safely, we do share information in the following specific circumstances:

With Other NaijaCupid Members (Public Profile Information):

• Information you choose to display on your public profile is visible to other verified members. This includes your photos, bio, age, location (city/state), interests, and preferences.
• You Control Visibility: Through your privacy settings, you can limit who sees certain parts of your profile.
• Your private messages remain confidential between you and the recipient, unless you report an issue to our safety team — in which case those messages may be reviewed and retained as part of our enforcement process.

With Service Providers & Partners (Under Strict Agreements):

We work with carefully vetted third-party companies that help us operate NaijaCupid. These partners may only access your data to perform specific services on our behalf and are bound by confidentiality and data protection agreements. Categories include:

• Cloud hosting and infrastructure providers
• Payment processors (e.g., Paystack)
• Email and notification service providers
• Analytics and product optimisation tools
• Customer support software providers
• Cybersecurity and fraud detection services
• Legal, accounting, and compliance advisors

For Legal Compliance, Platform Protection & Safety:

• Law Enforcement Requests: If we receive a valid legal request from Nigerian police, courts, or regulatory authorities, we may be legally required to disclose relevant data.
• Safety Emergencies: If we believe disclosure is necessary to prevent serious harm, protect a person's life, or investigate potential crimes, we may share information with relevant authorities without notice.
• Protection of NaijaCupid's Rights: We may disclose data where necessary to investigate, pursue, or defend against fraudulent claims, chargeback disputes, intellectual property violations, Terms of Service breaches, or any legal proceedings brought against or by LonerTech Ltd. This includes sharing data with our legal representatives, insurers, and relevant courts.
• Enforcement of Bans: In cases of permanent account termination for misconduct, we may retain and share relevant data with internal systems or partner platforms where necessary to prevent re-registration or re-entry to the platform by banned individuals.

Business Transfers:

If LonerTech Ltd is acquired, merges with another business, or undergoes restructuring, your data may be transferred as part of that transaction. We would notify you in advance and ensure the acquiring entity maintains equivalent privacy protections.

Aggregated & Anonymised Data:

We may share statistical information that cannot identify you personally for research, reporting, and business improvement purposes.

4. Your Privacy Rights Under the NDPR

The Nigeria Data Protection Regulation gives you important rights over your personal information. Here is what you can do, and how:

Right to Access Your Data:

You may request a copy of all personal data we hold about you. We will provide this in a readable electronic format within 30 days of a verified request.

How to exercise: Email privacy@naijacupid.com.ng with "Data Access Request" in the subject line.

Right to Rectification:

If any of your personal information is inaccurate or incomplete, you have the right to have it corrected. Most profile details can be updated directly through your account settings.

Right to Erasure ("Right to Be Forgotten"):

You may request deletion of your personal data. When you delete your account, we will remove your profile, photos, messages, and other personal information from active systems. However, we are entitled to retain data in the following circumstances, without limitation:

• To comply with legal or regulatory obligations (including tax records and financial documentation, typically for 7 years under Nigerian law)
• To protect other users — for example, records of accounts banned for scamming, harassment, or platform abuse are retained indefinitely to prevent re-registration and protect the community
• To investigate and resolve disputes, complaints, chargeback claims, or legal proceedings (retained until full resolution plus a reasonable period thereafter)
• To defend NaijaCupid's legal rights and interests in any current or reasonably foreseeable claim
• During backup retention periods of up to 90 days

How to exercise: Delete your account through account settings, or email privacy@naijacupid.com.ng.

Right to Withdraw Consent:

For data processing based on your consent, you may withdraw that consent at any time. Withdrawal does not affect any processing already carried out.

Right to Object to Processing:

If we are processing your data on the basis of legitimate interests, you may object. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests — including, but not limited to, the protection of the platform, its users, and NaijaCupid's legal rights.

Right to Data Portability:

You may request your personal data in a commonly used, machine-readable format so you can transfer it to another service. Email privacy@naijacupid.com.ng with "Data Portability Request" in the subject line.

Right to Restrict Processing:

In certain situations — such as challenging data accuracy or objecting to processing — you may request that we limit how we use your data while the matter is resolved.

Right to Lodge a Complaint:

If you believe we have violated your privacy rights, you may file a complaint with:

• Our Data Protection Officer first: privacy@naijacupid.com.ng
• Nigeria Data Protection Commission (NDPC): https://ndpc.gov.ng (if unsatisfied with our response)

5. Cookies & Tracking Technologies

Like most websites and apps, NaijaCupid uses cookies and similar technologies. Here is what that means in practical terms:

What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us recognise you, remember your preferences, and improve your experience. They also help us detect abuse, prevent fraud, and enforce our Terms of Service.

Essential Cookies (Required for Basic Functionality):

• Authentication and session management — keeping you logged in
• Security and fraud detection — identifying suspicious activity and protecting accounts
• Platform integrity — detecting and preventing ban circumvention and multiple account creation
• Load balancing and performance

These cookies are necessary for the platform to function. Disabling them will prevent you from using NaijaCupid. Because they serve platform security and integrity functions, they cannot be opted out of while you use the service.

Functional Cookies (Remember Your Preferences):

• Language and display preferences
• Notification settings
• Recently viewed profiles

Analytics Cookies (Help Us Improve):

• Feature usage and engagement tracking
• Page performance and load time measurement
• Technical issue identification

Marketing Cookies (Optional):

• Interest-based advertising
• Campaign effectiveness measurement

How to Control Non-Essential Cookies:

When you first visit NaijaCupid, you will see a cookie consent banner allowing you to customise your preferences. You may also adjust settings through your browser. Note that blocking non-essential cookies does not affect our ability to use essential security and integrity cookies.

6. How Long We Keep Your Data

We do not keep your personal information indefinitely beyond what is necessary. Our retention practices are as follows:

While Your Account is Active:

We retain all profile information, messages, photos, and activity data for as long as your account remains open.

After Account Deletion:

• Immediate: Your profile becomes invisible to other users and your personal details are removed from active systems within 72 hours.
• Messages: Messages you sent may remain visible in recipients' inboxes (as part of their conversation history), but will display as "Deleted User."
• Backups: Data may persist in backup systems for up to 90 days before permanent purging.

Data We Are Entitled to Retain Indefinitely or for Extended Periods:

• Banned Account Records: Where an account has been terminated due to fraud, scamming, harassment, underage use, or other platform abuse, we retain records of that termination — including relevant profile data, messages, and evidence — indefinitely to protect the platform and prevent re-registration.
• Dispute & Legal Hold Data: Where data is relevant to a dispute, chargeback claim, complaint, or legal proceeding, we retain it until full resolution of the matter plus a minimum period of 3 years thereafter.
• Financial Records: Transaction records are retained for a minimum of 7 years in compliance with Nigerian tax and financial regulations.
• Abuse Reports: Reports submitted about other users, along with supporting evidence, are retained for a minimum of 12 months and may be retained longer where relevant to ongoing enforcement or legal matters.
• Anonymised Analytics: Aggregated, non-identifiable statistical data is retained indefinitely.

Inactive Accounts:

If you have not logged into NaijaCupid for 24 consecutive months, we will send you reminder emails. If you do not respond within 30 days, we may deactivate your account and begin data deletion processes, consistent with our retention policy above.

7. How We Protect Your Data

LonerTech data security is one of our highest priorities. We invest in protecting your information from unauthorised access, theft, loss, or misuse:

Encryption Technology:

• All data transmitted between your device and our servers is encrypted using TLS/SSL encryption
• Sensitive data at rest is encrypted using AES-256
• Passwords are stored using bcrypt hashing with salts — never in plain text

Access Controls:

• Principle of least privilege — staff access only what their role requires
• Multi-factor authentication on internal systems
• Comprehensive audit logs of all data access

Infrastructure Security:

• Certified data centres with physical security measures
• Firewalls, intrusion detection systems, and DDoS protection
• Regular security audits and third-party penetration testing

Employee Practices:

• Mandatory privacy and security training for all staff
• Strict confidentiality agreements
• Clear incident response and escalation procedures

In the Event of a Data Breach:

Despite our best efforts, no system is entirely risk-free. If we experience a breach that poses a risk to your rights and freedoms, we will:

• Notify affected users within 72 hours of discovering the breach
• Report the incident to the Nigeria Data Protection Commission as required by the NDPR
• Provide clear information about what data was affected and what steps you should take
• Take immediate action to contain the breach and prevent recurrence

8. International Data Transfers

NaijaCupid primarily operates within Nigeria, but modern internet infrastructure sometimes requires data to cross borders.

When and Why Data May Be Transferred:

• Cloud hosting services with servers in multiple jurisdictions
• Third-party analytics, support, or payment tools operating internationally
• Business operations, legal proceedings, or regulatory requirements involving entities outside Nigeria

How We Protect Your Data in International Transfers:

• Adequacy Assessments: We only transfer data to jurisdictions with adequate protections or to entities contractually bound to maintain NDPR-equivalent standards.
• Data Processing Agreements: All international service providers sign agreements containing NDPR-compliant data protection clauses.
• Standard Contractual Clauses: Legal mechanisms binding international partners to Nigerian protection standards.

Regardless of where your data is physically stored or processed, you retain all the same rights described in Section 4 of this policy.

9. Children's Privacy: We Are for Adults Only

NaijaCupid is exclusively for adults aged 18 years and older. We take this restriction very seriously.

Our Commitment:

• We do not knowingly collect personal information from anyone under 18
• Account creation requires date of birth confirmation
• Our Terms of Service explicitly prohibit minors from using the platform
• We actively monitor for and remove underage accounts

If We Discover a Minor Has Created an Account:

• We will immediately suspend and permanently delete the account and all associated data
• We will take steps to prevent that individual from creating future accounts
• We will retain a record of the termination for platform protection purposes

If you believe a minor has created an account on NaijaCupid, please contact us immediately at privacy@naijacupid.com.ng.

10. Platform Conduct, Misuse & Data Use in Enforcement

NaijaCupid reserves the right to collect, retain, and use any personal data reasonably necessary to detect, investigate, and respond to violations of our Terms of Service, including prohibited conduct, fraudulent activity, identity misrepresentation, and abuse of other users.

This includes but is not limited to:

• Investigation of Reports: When you report another user, or when you are reported by another user, we may review messages, profile information, activity logs, device data, and any other relevant information to investigate and resolve the matter.
• Enforcement Actions: If we terminate your account for misconduct, we retain the data supporting that decision for as long as necessary to prevent re-registration, defend against appeals or legal claims, and cooperate with any regulatory or law enforcement inquiries.
• Fraud & Chargeback Prevention: Where you initiate or threaten a fraudulent payment dispute or chargeback claim, we may retain and use all available transaction data, communication records, and account history to defend NaijaCupid's rights and pursue recovery of any amounts wrongfully reversed. This data will be retained for a minimum of 7 years or until all dispute proceedings are fully resolved.
• Legal Proceedings: If any legal claim is brought by you or against you in connection with your use of NaijaCupid, we are entitled to retain and disclose any data relevant to that claim for the duration of those proceedings and for a reasonable period thereafter.
• Misrepresentation: If you have provided false information during registration or use of the platform — including false age, identity, photographs, or relationship status — that constitutes a breach of our Terms of Service. We reserve the right to retain evidence of such misrepresentation indefinitely for enforcement and legal protection purposes, even after account deletion.

11. Limitation of Our Liability Regarding Privacy

While NaijaCupid takes robust measures to protect your data, we draw your attention to the following important limitations of liability in connection with privacy and data matters:

• Information You Voluntarily Share: NaijaCupid is not responsible for any consequences arising from information you choose to share publicly on your profile or in private messages with other users. Exercise caution in what you disclose.
• Third-Party Actions: We are not liable for the actions of other users who misuse information shared with them through the platform. Our responsibility is limited to the security of data within our control.
• Third-Party Services: When you access or use third-party services linked from NaijaCupid, those services are governed by their own privacy policies. We are not responsible for their data practices.
• Data Breaches Beyond Our Control: Despite our security measures, we cannot guarantee absolute security. To the fullest extent permitted by Nigerian law, our liability in the event of an unauthorised data breach is limited to reasonable steps to notify you and mitigate harm, as described in Section 7.
• Aggregated/Anonymised Data: We are not liable for any claim arising from the use of data that has been fully anonymised and therefore no longer constitutes personal data under the NDPR.
• User-Caused Exposure: We are not responsible for privacy loss resulting from a user sharing their own account credentials, leaving their device unlocked, or otherwise enabling unauthorised access through their own conduct.

Nothing in this Section limits rights you may have under Nigerian law that cannot be excluded by agreement. To the fullest extent permitted by applicable law, NaijaCupid's total liability to you for any privacy-related claim shall not exceed the greater of: (a) the amount you paid to us in the 12 months preceding the event giving rise to the claim; or (b) Five Thousand Naira (NGN 5,000).

12. Changes to This Privacy Policy

As NaijaCupid grows and evolves, we may update this Privacy Policy to reflect new features, legal requirements, or changes in how we handle data.

• Notice of Changes: We will post the updated policy on this page with a revised "Last Updated" date.
• Significant Changes: For material changes that significantly affect how we use your data, we will notify you by email or prominent in-platform notice before they take effect.
• Your Acceptance: Continued use of NaijaCupid after any policy update constitutes your acceptance of the revised policy. If you disagree with material changes, you may delete your account before they take effect.
• No Reduction of Protections Without Notice: We will not materially reduce your privacy protections without clear advance notice.
• Enforcement & Platform Protection Provisions: Updates to provisions protecting NaijaCupid's legal rights and platform integrity (including Sections 10 and 11 above) may take effect immediately upon posting, as they are necessary to respond to evolving risks and legal requirements.

13. Governing Law and Jurisdiction

This Privacy Policy and all data protection practices are governed by the laws of the Federal Republic of Nigeria, including:

• The Nigeria Data Protection Regulation (NDPR) 2019
• The Nigeria Data Protection Act (NDPA) 2023
• Relevant provisions of the Constitution of the Federal Republic of Nigeria 1999 (as amended)
• The Federal Competition and Consumer Protection Act 2018
• Other applicable Nigerian privacy and consumer protection laws

Dispute Resolution:

Any disputes arising from this Privacy Policy or our handling of your personal data will be resolved in accordance with the dispute resolution provisions of our Terms of Service, which are incorporated herein by reference. The primary jurisdiction is Lagos State, Nigeria, where LonerTech Ltd is registered and operates. We encourage you to contact our Data Protection Officer in the first instance — most privacy concerns can be resolved quickly through direct communication.

Indemnification:

By using NaijaCupid, you agree to indemnify and hold harmless LonerTech Ltd, its directors, officers, employees, and agents from and against any claims, losses, damages, costs, or expenses (including reasonable legal fees) arising from or related to: (a) your misuse of personal data belonging to other users obtained through the platform; (b) any false information you provide in connection with your account or any privacy-related claim you make; or (c) your breach of this Privacy Policy or our Terms of Service.

14. Contact Us: Your Privacy Team

We are here to help with any privacy questions, concerns, or requests. Your privacy matters to us, and we want you to feel confident about how your data is handled.

Data Protection Officer (DPO):

• Email: privacy@naijacupid.com.ng
• Response Time: We aim to respond within 48 business hours and resolve most requests within 30 days
• Postal Address: LonerTech Ltd, Data Protection Officer, Lagos, Nigeria

What You Can Contact Us About:

• Exercising any of your NDPR rights (access, deletion, rectification, portability, etc.)
• Questions about how your data is used or shared
• Concerns about data security or suspected breaches
• Withdrawing consent for specific data processing activities
• Complaints about alleged privacy violations
• Requesting clarification on any part of this policy
• Reporting suspected underage users or platform abuse

General Customer Support:

For non-privacy questions (technical issues, account help, billing), please visit our Contact Page or use the in-app support feature.

Regulatory Authority:

• Nigeria Data Protection Commission (NDPC)
• Website: https://ndpc.gov.ng
• Email: info@ndpc.gov.ng

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Effective Date: November 17, 2025
Last Updated: May 24, 2026
Version: 3.0

Company Information:
LonerTech Ltd (Operating as NaijaCupid)
Registered in Nigeria
Primary Location: Lagos, Nigeria

This Privacy Policy is part of our commitment to NDPR compliance and represents our binding agreement with you regarding data protection standards on the NaijaCupid platform. By using NaijaCupid, you acknowledge that you have read, understood, and agreed to this Privacy Policy and our related Terms of Service.