Privacy Policy

1. Who We Are (Data Controller)

The data controller responsible for your personal information is Paperworks First Real Nigeria Limited, trading as MyLagosApp, with its registered office at 13, Olu-Akerele Street, Ikeja, Lagos. Nigeria. Email: info@mylagosapp.mobi.

2. Personal Data We Collect

2.1 Account and Identity Data

When you register, we collect your full name, email address, phone number, username, encrypted password, and profile photograph (if you upload one).

2.2 Device and Technical Data

We automatically collect device type, operating system version, unique device identifiers, mobile network information, browser type, and IP address.

2.3 Usage and Activity Data

Pages viewed, features accessed, searches conducted, reports submitted, session duration, links clicked, and application crash and error data.

2.4 Location Data

Where you grant permission, we collect precise real-time GPS location data to deliver location-relevant features such as traffic updates, nearby market listings, and local security alerts. You may withdraw location permission at any time through your device settings.

2.5 Communications Data

Records of your communications with us, including your contact details and the content of your messages, retained when you contact us for support or report an issue.

2.6 User-Generated Content

Content you submit to the platform including traffic reports, security alerts, news tips, reviews, comments, and photographs.

2.7 Payment Data

Payment processing is handled by third-party payment processors (including app stores). We do not store full payment card details on our servers.

2.8 Notification Preferences and Consent Records

Your push notification preferences, marketing consents, and other consent-based communication settings.

3. How We Collect Your Data

We collect personal data through: direct interaction (registration, profile updates, content submissions, contacting us); automated technologies (cookies, log files, pixels, and tracking tools); third-party platforms (Google Play Store, Apple App Store, analytics providers, where permitted by those platforms); and device sensors (GPS and other sensors where you have granted permission).

4. Legal Basis for Processing (NDPR 2019)

• Consent (NDPR Art. 2.2(a)): For push notifications, location tracking, and marketing. You may withdraw consent at any time without affecting prior lawful processing.
• Contract (NDPR Art. 2.2(b)): For creating and maintaining your account and delivering the services you have requested.
• Legal obligation (NDPR Art. 2.2(c)): To comply with applicable Nigerian law, including the Cybercrimes Act 2015 and the FCCPC Act 2018.
• Legitimate interests (NDPR Art. 2.2(e)): For fraud prevention, security monitoring, and service improvement, provided these interests are not overridden by your fundamental rights and freedoms.

5. How We Use Your Personal Data

• Account management and identity authentication
• Delivering, personalising, and improving platform features and services
• Providing real-time traffic, security, and location-based information
• Sending push notifications (with your consent)
• Responding to support enquiries and resolving disputes
• Detecting, investigating, and preventing fraud, abuse, and unauthorised access
• Analytics, performance monitoring, and continuous service improvement
• Complying with legal obligations and protecting our legal rights
• Sending marketing communications (with your consent)

6. Sharing Your Personal Data

We do not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data only in the following limited circumstances:

• Trusted service providers: Cloud hosting, analytics, customer support, and communications providers contracted to process data only on our instructions and in compliance with the NDPR.
• Legal requirements: Where required by applicable law, court order, or a competent Nigerian government or law enforcement authority.
• Protection of rights: Where necessary to protect the rights, property, or safety of the Company, our users, or the general public.
• Business transfers: In a merger, acquisition, or asset sale, your data may transfer to the successor entity with prior notice.
• With your consent: For any other purpose for which you have given express prior consent.

7. International Data Transfers

Your personal data may be transferred to and stored on servers outside Nigeria. Where such transfers occur, we take appropriate safeguards to ensure protection consistent with the NDPR, including through contractual data protection clauses with receiving parties.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies (web beacons, local storage) to remember preferences, understand usage patterns, improve performance, and deliver personalised content. We use strictly necessary cookies (essential, cannot be disabled), analytics cookies (with consent), and functional cookies (personalisation). You can manage or disable cookies through your browser settings, though doing so may affect website functionality.

9. Push Notifications

With your consent, we send push notifications for traffic updates, security alerts, news, and platform events. You may withdraw consent at any time through the application or your device settings. Withdrawal does not affect notifications sent prior to withdrawal.

10. Location Data

We collect precise location data only with your explicit device-level permission, used solely to provide geographically relevant services. We do not share your real-time location with third parties beyond what is described in Section 6. You may revoke location permission at any time through your device settings, which may limit certain platform features.

11. Data Retention

• Account data: Retained for the duration of your account and up to 12 months after deletion, then securely deleted or anonymised.
• Usage and log data: Up to 12 months for security and analytics purposes.
• Support and communications records: Up to 3 years for dispute resolution and compliance.
• Legal compliance records: Up to 7 years as required by applicable Nigerian law.

12. Security of Your Data

We implement TLS/SSL encryption of data in transit, secure password hashing, role-based access controls restricting data access to authorised personnel on a need-to-know basis, regular security assessments, and staff data protection training. No electronic transmission is 100% secure. In the event of a personal data breach likely to pose risk to your rights and freedoms, we will notify NITDA and, where required, affected data subjects in accordance with the NDPR.

13. Your Rights Under the NDPR 2019

• Right of access: Obtain confirmation of whether we process data about you and receive a copy of your personal data.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of data no longer needed, where consent is withdrawn, or where processing is unlawful. See our Remove My Account page.
• Right to data portability: Receive your data in a structured, machine-readable format.
• Right to restriction of processing: Request restricted processing in certain circumstances.
• Right to object: Object to processing based on legitimate interests, or to direct marketing processing.
• Right to withdraw consent: Withdraw consent at any time without affecting prior lawful processing.

To exercise any right, email info@mylagosapp.mobi with the subject line Data Subject Request. We will respond within 30 days in accordance with NDPR requirements and may verify your identity before processing. We will not charge a fee in normal circumstances.

14. Children's Privacy

MyLagosApp is not directed at children under 13. We do not knowingly collect personal data from children under 13 without verifiable parental consent. If you are a parent or guardian and believe your child has provided us with data without consent, please contact us immediately at info@mylagosapp.mobi.

15. Changes to This Privacy Policy

We may update this policy to reflect changes in our data practices, new legal requirements, or service improvements. Material changes will be communicated by updating the Effective Date, displaying an in-app notice, and/or emailing your registered address. Continued use of MyLagosApp following an update constitutes acceptance of the changes.

16. Contact Us and Complaints

For questions, concerns, or data subject requests, contact us:

• Email: info@mylagosapp.mobi (Subject: Privacy Enquiry or Data Subject Request)
• Post: Data Protection Team, Paperworks First Real Nigeria Limited, 13, Olu-Akerele Street, Ikeja, Lagos. Nigeria.

If you are not satisfied with our response, you have the right to lodge a complaint with NITDA, the supervisory authority for data protection in Nigeria: www.nitda.gov.ng • ndpr@nitda.gov.ng.