1.0. INTRODUCTION

At SKILLWAVE SMART LIMITED (the "Company"), we respect the privacy of our users and are committed to protecting their personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard the personal data of freelancers, employers, and other visitors to our platforms, which includes our website and mobile application.

When you use our services, provide us with details of your Personal Data or click on the “accept” button, you accept this Privacy Policy and hereby give us consent to save, process and use your Personal Data to the extent as allowed by law.

We encourage you to review our Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy.

2.0. INFORMATION WE COLLECT

We collect both personal and non-personal information from users, including but not limited to:

2.1. Personal Information:

1. Full name
2. Contact details (email address, phone number)
3. Identification documents (e.g., national ID, passport)
4. Payment and financial information (e.g., bank account details)
5. Business details (for employers, where applicable) such as business name, address, and other necessary information/documents;

2.2. Non-Personal Information:

1. Usage data such as IP addresses, device information, browser type, and platformusage analytics
2. Cookies and tracking information to enhance user experience and trackwebsite/app performance.

3.0. HOW WE USE INFORMATION

We use the information we collect for the following purposes:

1. User Account Management: To verify users' identities (KYC process), facilitate user account creation, and provide access to our services.
2. Transaction Processing: To process payments, withdrawals, and other financial transactions between freelancers and employers on the platform.
3. Communication: To send notifications about products, services, offers, promotions, rewards, and events offered by the Company and others and other relevant communications related to account activities, security alerts, and changes to our services or policies.
4. Compliance and Security: To comply with applicable legal and regulatory obligations, including AntiMoney Laundering (AML) requirements, and to ensure the security and integrity of our platform by monitoring for suspicious or illegal activities.
5. Monitor and analyse trends, usage and activities in connection with our services.
6. Personalize and improve the services and provide advertisements, content or features that match user profiles or interests.
7. Process and deliver contest or promotion entries and rewards.
8. Link or combine with information we get from others to help understand your needs and provide you with better service.
9. Carry out any other purpose for which the Personal Data was collected.
10. Improvement of Services: To analyze user interactions and improve the functionality, content, and overall user experience on the platform.

4.0. LEGAL BASIS FOR PROCESSING

We process personal data based on the following legal grounds:

1. Consent: By using our platform and providing your information, you consent to the collection and processing of your data.
2. Contractual Necessity: We process personal data to fulfill our contractual obligations with users.
3. Legal Obligation: To comply with legal and regulatory requirements, particularly regarding AML and KYC regulations.
4. Legitimate Interests: We may process data where necessary for our legitimate business interests, such as fraud prevention, service improvement, and platform security.

Skillwavesmart Limited is based in Nigeria and the information we collect is governed by the Nigerian Data Protection Regulation (NDPR) and the Nigerian Data Protection Act (NDPA). By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to Nigeria [and other countries].

5.0. DATA RETENTION

We retain personal information for as long as it is necessary to fulfill the purposes outlined in this policy, comply with legal obligations, resolve disputes, and enforce agreements. Data related to financial transactions and compliance with regulatory requirements (e.g., AML laws) will be retained for the required period under Nigerian law.

6.0. SHARING OF INFORMATION

We may share personal information with third parties in the following circumstances:

1. Service Providers: We share information with third-party service providers that assist with identity verification, payment processing, and other business operations.We require that these parties agree to process such Personal Data based on our instructions and in compliance with the Nigeria Data Protection Act (NDPA) and any other appropriate confidentiality and security measures. When they no longer need your Personal Data to fulfil this service, they will dispose of the details in line with the NDPA. With other third-parties such as email service providers that perform marketing services on our behalf.
2. Legal Compliance: We may disclose personal data to law enforcement agencies, government authorities, or other third parties if required by law or in connection with a legal claim or investigation.
3. Business Transfers: In the event of a merger, acquisition, or asset sale, personal data may be transferred to the acquiring entity.
4. With your consent or at your direction, including if we notify you that the Personal Data you provide will be shared in a particular manner and you provide such Personal Data.
5. We may also share aggregated or de-identified or anonymized Information, which cannot reasonably be used to identify you.

When we do not have a lawful basis for disclosure of your Personal Data, we will obtain consent from you before sharing your Personal Data with third parties. Where we need to transfer your Personal Data to another country, such country must have an adequate data protection law. We will seek your consent where we need to send your Personal Data to a country without an adequate data protection law

[We do not sell, trade, or rent users' personal information to third parties for marketing purposes.]

7.0. USER RIGHTS

Under the Nigerian law and applicable data protection regulations (including the Nigerian Data Protection Regulation (NDPR)and the Nigerian Data Protection Act (NDPA), users have the following rights regarding their personal data:

1. Access: Users can request access to their personal information stored by the Company.
2. Correction: Users can request the correction of inaccurate or incomplete personal data.
3. Erasure: Users may request the deletion of their personal information under certain circumstances, except where retention is required by law.
4. Restriction of Processing: Users can request the limitation of how their personal data is processed.
5. Data Portability: Users can request to receive a copy of their personal data in a structured, commonly used format.
6. Objection: Users can object to the processing of their data for certain purposes, such as marketing or direct sales.
7. Lodge Complaint – You have a right to lodge a complaint about the handling of your Personal Data with the Nigeria Data Protection Commission (NDPC) at info@ndpc.gov.ng

NDPC’s website (https://ndpc.gov.ng) has a wealth of useful information in respect of your rights over your Personal Data.To exercise these rights, users may contact us using our contact information on our platforms.

8.0. DATA SECURITY

We take the security of our users' data seriously and have implemented appropriate technical and organizational measures to safeguard personal informationfrom loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. These measures include:

• Data encryption and secure storage
• Regular audits and risk assessments
• Secure access controls to restrict unauthorized access to sensitive data

However, no online platform is entirely risk-free, and as such, users are encouraged to use strong passwords and take precautions to protect their accounts at all times.

9.0. COOKIES AND TRACKING TECHNOLOGIES

Our platform uses cookies and other tracking technologies to enhance user experience and collect information about platform usage. Users can control cookie preferences through their browser settings.

10.0. THIRD PARTY LINKS

Our platform may contain links to third-party websites or services. This Privacy Policy does not apply to third-party sites, and we are not responsible for the privacy practices of those websites. We encourage users to review the privacy policies of those third parties before onward interactions with such.

11.0. INTERNATIONAL DATA TRANSFERS

While our operations are primarily based in Nigeria, user data may be transferred to, stored, or processed in other jurisdictions where our third-party service providers are located. We will ensure that any international data transfers comply with applicable data protection laws and provide adequate protection for users’ personal data.

12.0. CHANGES TO THIS POLICY

We reserve the right to update this Privacy Policy from time to time to reflect changes in our business, services or legal obligations. Users will be notified of any significant changes via email or platform notifications. Continued use of our services following changes to the policy will be deemed as acceptance of those changes.

13.0. CONTACT US

If you have any questions or concerns about this Privacy Policy or would like to contact us for any reason, you can contact us on using any of our contact options listed on our platforms.