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:
- Visit our website here, or any
website of ours that links to this Privacy Notice.
- Download and use our mobile application ( Spotix for users, Spotix for
bookers, Spotix for admins) , or any other application of ours that links to this Privacy Notice.
- Engage with us in other related ways, including any sales, marketing,
or events.
- Use Spotix. Spotix is an innovative online platform designed to
streamline the event planning and ticketing process for both event organizers and attendees. Our
mission is to provide a seamless, user-friendly, and secure environment for discovering, planning,
and attending events. Key features include:
- Event Creation and
Management: Event planners can easily create and manage their
events, including setting ticket prices, availability, and event details.
- Ticket Purchasing and
Sales: Users can browse and purchase tickets for various events,
with secure payment processing and instant ticket delivery.
- Event
Discovery: Users can discover new events based on their interests,
location, and preferences.
- Personalized Event
Recommendations: Our algorithm provides personalized event
recommendations to users based on their event history and preferences.
- Real-time Event
Updates: Event planners can send real-time updates to attendees,
ensuring everyone stays informed about event changes or cancellations.
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.
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:
- To facilitate account creation and authentication and otherwise manage user accounts:
We may process your information so you can create and log in to your account, as well as
keep your account in working order.
- To advance user roles: We may process your information manually or automated means
to advance your user roles in Spotix to allow you access to more services
- To provide identity authenticity: We may process your information to verify
authenticity of individuals making use of our Services
- To get analytics: We may process your information while gathering analytics of
users using our product.
- Initiating Payouts: We may request for some information to process payouts. Please
note that we will only request for information that pertains to payout of a particular service and
we only make such requests from our official in bound platforms
- To save or protect an individual's vital interest: We may process your information
when necessary to save or protect an individual’s vital interest, such as to prevent harm.
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:
- Consent: We may process your information if you have given us permission (i.e.
consent) to use your personal information for a specific purpose. You can withdraw your consent at
any time. Learn more about withdrawing your consent.
- Legal Obligations: We may process your information where we believe it is necessary
for compliance with our legal obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in
litigation in which we are involved.
- Vital Interests: We may process your information where we believe it is necessary
to protect your vital interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.
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:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a
timely way.
- For investigations and fraud detection and prevention.
- For business transactions provided certain conditions are met.
- If it is contained in a witness statement and the collection is necessary to assess, process, or
settle an insurance claim.
- For identifying injured, ill, or deceased persons and communicating with next of kin.
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial
abuse.
- If it is reasonable to expect collection and use with consent would compromise the availability or
the accuracy of the information and the collection is reasonable for purposes related to
investigating a breach of an agreement or a contravention of the laws of Nigeria or an AU state.
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records.
- If it was produced by an individual in the course of their employment, business, or profession and
the collection is consistent with the purposes for which the information was produced.
- If the information is publicly available and is specified by the regulations.
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:
- Business Transfers: We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a
portion of our business to another company.
- Affiliates: We may share your information with our affiliates, in which case we
will require those affiliates to honour this Privacy Notice. Affiliates include other products
offered by Spotix and any subsidiaries of that product or current product, joint venture partners,
or other companies that we control or that are under common control with us.
- Business Partners: We may share your information with our business partners to
offer you certain products, services, or promotions. Such as any of our payment partners, designated
logistics team or bookers whom may have access to specific user data.
- Offer Wall: Our application(s) may display a third-party hosted 'offer wall'. Such
an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to
users in return for the acceptance and completion of an advertisement offer. Such an offer wall may
appear in our application(s) and be displayed to you based on certain data, such as your geographic
area or demographic information. When you click on an offer wall, you will be brought to an external
website belonging to other persons and will leave our application(s). A unique identifier, such as
your user ID, will be shared with the offer wall provider in order to prevent fraud and properly
credit your account with the relevant reward.
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.
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 .