Your data, explained.

1. Who we are

TapPay Limited (“TapPay”, “we”) runs the TapPay waitlist and referral rewards campaign and decides how your personal data is used for it.

Privacy contact: [DPO name and email to be added]

2. What we collect

• Your full name and email address (required to join).
• Your phone number (optional).
• Your referral code, and a count of friends who joined through your link.
• A record of when you agreed to these terms, which version, and your SMS choice.
• A scrambled (hashed) version of your IP address, used only to stop abuse. We don't store the address itself.

3. Why we use it, and our legal basis

• To run the waitlist and email you launch updates: with your consent.
• To text your launch-day invite: only if you tick the optional SMS box, and you can withdraw at any time.
• To count referrals and award points: to deliver the campaign you signed up for.
• To prevent fraud and fake sign-ups: our legitimate interest in keeping the campaign fair.

4. Who we share it with

We don't sell your data. Our hosting provider stores it, and our email provider, Zoho (ZeptoMail), sends your confirmation emails. Both act on our instructions under a written agreement. A small number of TapPay staff can open the waitlist, and every view and export is logged.

5. Where it's stored

Your data is stored on servers in Germany, so it leaves Nigeria. Germany is in the European Union, which has strong data protection law, and we protect your data with a written agreement with our hosting provider, as the Nigeria Data Protection Act requires. [confirm the safeguard wording with counsel] Zoho handles your name and email address to deliver our messages, through its data center in the United States [confirm the Zoho region and add it to the safeguards above].

6. How long we keep it

• Sign-ups that never confirm their email: deleted after [30 days].
• Everyone else: until [period after launch], unless you become a TapPay app user, in which case your app account terms apply.
• If you delete your data, we keep only a scrambled copy of your email so you aren't added again by mistake.

7. Your rights

You can ask to see your data, correct it, delete it, limit how we use it, object to its use, or receive a copy to take elsewhere. You can withdraw consent at any time without giving a reason. Use the controls on your waitlist page, or contact us at [privacy email]. We'll reply within [timeframe].

8. How we protect it

• Every connection is encrypted (HTTPS).
• Phone numbers are stored encrypted.
• Only a few TapPay staff can open the waitlist, they see phone numbers masked, and every view and export is recorded.
• If a breach puts your data at risk, we'll tell you and the Nigeria Data Protection Commission, as the law requires.

9. Children

The waitlist is for people aged 18 and over. If you think a child has signed up, contact us and we'll delete the entry.

10. Complaints

If you're unhappy with how we handle your data, tell us first. You can also complain to the Nigeria Data Protection Commission (NDPC).

11. Changes to this notice

If we change this notice we'll update the date on this page and email you if the change matters. [Last updated: date]