PRIVACY POLICY

Last Updated: May 05, 2025

This Privacy Notice for for Spotix PLC (doing business as Spotix) ('we', 'us', or 'our' ), describes how and why we might access, collect, store, use, and/or share ( 'process') your personal information when you use our services ( 'Services'), including when you:

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@spotix.com.ng.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.
Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depnding on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting spotix.com.ng/DSA , or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENT

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  8. HOW LONG DO WE KEEP YOUR INFORMATION?
  9. HOW DO WE KEEP YOUR INFORMATION SAFE?
  10. DO WE COLLECT INFORMATION FROM MINORS?
  11. WHAT ARE YOUR PRIVACY RIGHTS?
  12. CONTROLS FOR DO-NOT-TRACK FEATURES
  13. DO NIGERIAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
  15. WHO IS A BOOKER?
  16. WHAT HAPPENS TO EVENTS OF A BOOKER AFTER THEY DELETE THEIR ACCOUNT?
  17. DO WE MAKE UPDATES TO THIS NOTICE?
  18. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  19. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Sensitive Information: Yes we do process sensitive information which includes but not limited to your address, pictures, NIN / BVN, banking information, Coporate documents etc. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information may not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. While interacting with certain third party services of Spotix such as our Telegram Bots may reveal some information about you on Telegram. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.

Classified Data

In Short: There are some specific information you upload to us that we may never allow you to access again.
Classified Data is voluntarily uploaded by you to us and we usually use this for any kind of verification. Data can only be classified as Classified data if it is being verified by our third party companies. Data such as Credit score, BVN/NIN, Student University ID, TPBs etc. Uploading incorrect classified data will probably lead to deactivation of your account pending when we delete the inconsistent data.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
If you are located in Nigeria or any AU state, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account , prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
Spotix also has inherent analytics system which allows us to monitor certain activities. Spotix ads unit allows us to monitor how our ads are interacted with both on Spotix and any third party service where our ads are shown which is governed by this clause. We may also use Spotix tracking systems to monitor how you interact with events on the platform for preference management and booker analytics.
To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section ' DO NIGERIAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? '
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice .

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If any of our products supports social login and you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Nigeria (Anambra[Central]) and United States (California & Rhode Island). If you are accessing our Services from outside Nigeria and United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see ' WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? ' above), in Nigeria, United States, and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
On our own end however, we have strict rules guarding use and access of data within our database. All third party partners who wish to access our data have to authenticate and re-authenticate themselves in our network before they can access our data. We constantly try to evolve our Cybersecurity provisions and we have persistent anti penetration testing methods to ensure smooth operation of our products. Additionally, we don't allow rooted devices use our apps and we ensure that we only serve users over a HTTPS network.

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age .
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@spotix.com.ng or make a report of an event posted by individuals less than 18 years to our Telegram Bot.

11. WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your state of residence in Nigeria, AU states, The US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada , you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada ), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ' below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS NOTICE? ' below or updating your preferences .
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:
  • Log in to your account settings and update your user account.
  • Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
    Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
    If you have questions or comments about your privacy rights, you may email us at support@spotix.com.ng .

    12. CONTROLS FOR DO-NOT-TRACK FEATURES

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ( 'DNT' ) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised . As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
    California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

    13. DO NIGERIAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
    Categories of Personal Information We Collect
    We have collected the following categories of personal information in the past twelve (12) months:
    Categories Examples Collected
    A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name YES
    B. Personal information as defined in the Nigerian Customer Records statute Name, contact information, education, employment, employment history, and financial information item
    C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data item
    D. Commercial information Transaction information, purchase history, financial details, and payment information item
    E. Biometric information Fingerprints and voiceprints item
    F. Internet or other similar network activity Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements item
    G. Geolocation data Device location item
    H. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities item
    I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us item
    J. Education Information Student records and directory information item
    K. Inferences drawn from collected personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics item
    We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
    • Receiving help through our customer support channels;
    • Participation in customer surveys or contests; and
    • Facilitation in the delivery of our Services and to respond to your inquiries.
    We will use all items we collect in the above categories as long as the user has an account with us. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

    Your Rights

    You have rights under certain Nigerian data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
    • Right to know whether or not we are processing your personal data: We may not disclose if we are processing some type of data such as in-app wallet data.
    • Right to access your personal data: Certain information such as all data uploaded for a verification process (Classified Data) will not be included for your review once sent.
    • Right to correct inaccuracies in your personal data: When we process certain data like classified data, inaccurate or inconsistent uploads will not be corrected.
    • Right to request the deletion of your personal data: We may withold your personal data especially those termed as classified
    • Right to obtain a copy of the personal data you previously shared with us: We may not share your classified data even with you again.
    • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling'): We may use your personal data with a Spotix product or any third party partner to serve you targetted recommendations in our products which you can't opt out.

    Request Verification for Personal Data

    Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
    If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

    14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: You may have additional rights based on the country you reside in.
    REPUBLIC OF SOUTH AFRICA
    At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?'
    If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

    10. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to children under 18 years of age .

    10. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to children under 18 years of age .

    10. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to children under 18 years of age .

    10. DO WE COLLECT INFORMATION FROM MINORS?

    In Short: We do not knowingly collect data from or market to children under 18 years of age .

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