Privacy Policy

Effective Date: January 10, 2026
Last Updated: January 10, 2026

1. INTRODUCTION

Welcome to Ezzyly ("we," "us," "our"), Nigeria's premier service marketplace app operated by Seer Global Solutions Limited, a Nigerian company and subsidiary of Seer Group Inc. (USA). This Privacy Policy explains how we collect, use, disclose, and protect your information when you use the Ezzyly mobile application and related services (collectively, the "Service") in Nigeria, with provisions for our planned expansion to other African countries and globally.

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our Service.

This policy complies with:

• Nigeria Data Protection Regulation (NDPR) 2019
• Nigeria Data Protection Act 2023
• Google Play Store User Data Policy
• Apple App Store Privacy Requirements
• Provisions for future compliance with GDPR, CCPA, and other international standards

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Registration

• Basic Information: Full name, email address, Nigerian phone number
• Age Verification: Date of birth (must be 18+ years old)
• Account Type: Customer or Service Provider designation
• Location: State, city, and service area within Nigeria

For Service Providers in Nigeria

• Identity Verification: 

• Government-issued Nigerian ID (NIN, Driver's License, Voter's Card, or International Passport)
• Selfie for facial verification
• BVN (Bank Verification Number) for payment processing

• Professional Information: 

• Services offered and categories
• Years of experience
• Professional certifications and licenses
• CAC registration (for registered businesses)
• Work samples/portfolio photos
• Service areas within Nigeria

• Financial Information: 

• Nigerian bank account details for daily payouts
• Mobile money accounts (OPay, PalmPay, Kuda, etc.)
• Tax Identification Number (TIN) where applicable

For Customers in Nigeria

• Service Preferences: Types of services needed, frequency, preferred providers
• Delivery Addresses: Home, office, or service locations within Nigeria
• Payment Methods: 

• Nigerian bank cards (Mastercard, Visa, Verve)
• Bank transfer details
• Mobile money accounts
• USSD payment preferences

2.2 Information Collected Automatically

Device and Technical Information

• Device Data: Device model, operating system (Android/iOS), app version, screen size
• Identifiers: Device ID, Advertising ID (with consent), IP address
• Network: Nigerian mobile carrier (MTN, Glo, Airtel, 9mobile), internet service provider
• Performance: App crashes, errors, system activity logs, battery usage

Usage Information

• App Activity: Features used, pages viewed, search queries, time spent
• Service Data: Booking history, service preferences, completion rates, cancellation patterns
• Interaction Data: Click patterns, feature engagement, user flow

Location Information

We collect location data for service delivery:

• Service Providers: Real-time location when marked "available" for jobs
• During Service: Route tracking for safety and verification
• Customers: Service delivery address
• All Users: City/state for showing available services

Important: Location services can be disabled in your device settings, but this will limit core functionality.

2.3 Information from Third Parties

• Verification Services: Results from Nigerian identity verification providers (Smile Identity, Youverify, IdentityPass, Dorjah)
• Payment Processors: Transaction confirmations from Paystack, Flutterwave, Interswitch
• Background Checks: Criminal record checks where available through Nigerian authorities
• Referral Programs: Information when other users refer you to the platform
• Social Media: If you choose to link accounts (name, profile picture)

3. HOW WE USE YOUR INFORMATION

3.1 To Provide Our Service

• Match customers with nearby service providers in Nigeria
• Process bookings and facilitate communication
• Handle payments in Nigerian Naira (₦)
• Provide daily payouts to Service Providers
• Send service notifications (booking confirmations, provider arrival)
• Provide customer support in English and Nigerian languages (Pidgin, Yoruba, Igbo, Hausa)
• Enable USSD booking for users without smartphones

3.2 For Safety and Trust

• Verify identities using Nigerian ID systems
• Validate BVN for secure payment processing
• Monitor for fraudulent activity
• Investigate complaints and policy violations
• Ensure platform safety for all Nigerian users
• Track service delivery for security
• Implement SOS/emergency features

3.3 To Improve Our Service

• Analyze usage patterns in different Nigerian cities
• Personalize service recommendations
• Test new features with select user groups
• Optimize our matching algorithm for Nigerian market
• Conduct market research for expansion within Nigeria
• Develop features specific to Nigerian user needs

3.4 For Communications

Service Communications (Always Sent):

• Booking confirmations and updates
• Payment receipts and payout notifications
• Safety alerts and security notifications
• Policy updates and legal notices
• Service availability in your area

Marketing Communications (With Your Consent):

• Promotional offers and discounts
• New feature announcements
• Service provider spotlights
• Partner offers from Nigerian businesses
• Survey and feedback requests

3.5 Legal Compliance

• Comply with Nigerian federal and state laws
• Respond to requests from Nigerian law enforcement agencies
• Report suspicious transactions to Nigerian Financial Intelligence Unit (NFIU)
• Comply with Central Bank of Nigeria (CBN) regulations
• Enforce our Terms of Service
• Protect rights, property, and safety
• Maintain records as required by Nigerian law

4. LEGAL BASIS FOR PROCESSING (NDPR)

Under the Nigeria Data Protection Regulation, we process your data based on:

• Contract Performance: To provide the services you requested
• Legal Obligations: To comply with Nigerian laws and regulations
• Legitimate Interests: For business operations, fraud prevention, and platform safety
• Consent: For marketing communications and optional features
• Vital Interests: In emergency situations to protect life or safety
• Public Interest: When required by Nigerian authorities

5. HOW WE SHARE YOUR INFORMATION

5.1 Between Users

What Customers See:

• Service Provider's name and profile photo
• Ratings and reviews
• Services offered and pricing
• General location (neighborhood/area, not exact address)
• Verification badges

What Service Providers See:

• Customer's first name
• Service location (after accepting booking)
• Phone number (after accepting booking)
• Special service instructions

5.2 With Service Partners

We work with trusted partners to operate our Service:

5.3 For Legal and Safety Reasons

We may share information when required to:

• Comply with Nigerian law or valid legal process
• Respond to requests from EFCC, Police, or other Nigerian law enforcement
• Report to NFIU for anti-money laundering compliance
• Protect the safety of users or the public
• Prevent fraud or criminal activity
• Protect our legal rights under Nigerian law

5.4 Business Transfers

If Seer Global Solutions Limited is involved in a merger, acquisition, or sale:

• Users will be notified before any transfer of data
• Privacy protections will continue under new ownership
• You may delete your account if you object to the transfer

5.5 Aggregated and Anonymized Data

We may share aggregated, non-identifiable data for:

• Nigerian market research and economic studies
• Transportation planning with Nigerian authorities
• Academic research with Nigerian universities
• Industry reports and insights

6. DATA STORAGE AND TRANSFERS

6.1 Data Storage

• Primary data storage is in secure cloud servers
• Sensitive payment data is stored with PCI-DSS compliant providers
• Some data may be processed in Nigeria for faster service

6.2 International Transfers

As we plan for international expansion:

• Data may be transferred to servers outside Nigeria
• We ensure appropriate safeguards per NDPR requirements
• Standard contractual clauses will be implemented
• You will be notified of significant changes

6.3 Data Localization

We comply with any Nigerian data localization requirements and will adapt as regulations evolve.

7. DATA RETENTION

We retain your information only as long as necessary:

8. YOUR PRIVACY RIGHTS UNDER NDPR

8.1 Your Rights as a Nigerian Data Subject

Under NDPR, you have the right to:

• Access: Request a copy of your personal data we hold
• Rectification: Correct inaccurate or incomplete information
• Erasure: Request deletion of your data ("right to be forgotten")
• Data Portability: Receive your data in a structured, machine-readable format
• Object: Opt-out of certain data processing activities
• Restrict Processing: Limit how we use your data
• Withdraw Consent: Change your mind about permissions at any time
• No Automated Decision-Making: Request human review of automated decisions

8.2 How to Exercise Your Rights

In the Ezzyly App:

• Go to Settings > Privacy > My Data Rights
• Select the right you want to exercise
• Follow the prompts

By Email:

• Send requests to: privacy@seerglobalsolutions.com
• Include your registered phone number
• We'll respond within 30 days

By Mail: Seer Global Solutions Limited
Data Protection Officer
Suite B 8, Real Tower Center
Plot 1121 Obafemi Awolowo Way
Utako District, FCT, Nigeria

8.3 Complaints

If you're not satisfied with our response, you may lodge a complaint with:

• National Information Technology Development Agency (NITDA)
• Email: info@nitda.gov.ng
• Website: www.nitda.gov.ng

9. DATA SECURITY

9.1 Technical and Organizational Measures

We protect your data through:

• Encryption: TLS 1.3 for data in transit, AES-256 for data at rest
• Access Controls: Role-based access, multi-factor authentication
• Security Audits: Regular penetration testing and vulnerability assessments
• Employee Training: Data protection and security awareness
• Incident Response: 24/7 monitoring and response team
• Vendor Management: Security assessments of all third parties

9.2 Your Security Responsibilities

• Use a strong, unique password
• Don't share your login credentials
• Keep your app updated to the latest version
• Report suspicious activity immediately to security@seerglobalsolutions.com
• Log out when using shared devices

9.3 Data Breach Notification

In case of a data breach affecting your personal data:

1. We will notify NITDA within 72 hours of discovery
2. We will notify affected users without undue delay
3. We will provide information about the breach and mitigation steps
4. We will implement measures to prevent future breaches

10. CHILDREN'S PRIVACY

Ezzyly is not intended for anyone under 18 years old. We do not knowingly collect data from children. If we discover a child has created an account, we will immediately delete it. Parents or guardians who believe their child has provided us information should contact us at privacy@seerglobalsolutions.com.

11. COOKIES AND TRACKING TECHNOLOGIES

11.1 Mobile App Tracking

11.2 Web Tracking (www.ezzyly.ng)

• Essential Cookies: Required for login and security
• Analytics Cookies: Help us improve the website
• Marketing Cookies: Only with your consent

11.3 Your Choices

• Manage cookie preferences through our cookie banner
• Disable tracking in app settings
• Use device-level controls for advertising preferences

12. THIRD-PARTY LINKS AND SERVICES

Our Service may contain links to third-party websites or services (banks, government portals, partner businesses). We are not responsible for their privacy practices. Please review their privacy policies before sharing your information.

13. APP STORE COMPLIANCE

13.1 Google Play Store Compliance

Data Safety Section Declarations:

• ✅ Data collected: Location, Personal info, Financial info, Photos, Device IDs
• ✅ Data sharing: Only with service providers for core functionality
• ✅ Data security: Encrypted in transit
• ✅ Data deletion: Users can request deletion
• ✅ NDPR compliant privacy policy

13.2 Apple App Store Compliance

App Privacy Details:

• Data Not Used to Track You: We don't track across apps/websites
• Data Linked to You: Contact info, User content, Identifiers, Usage data, Location
• Data Not Linked to You: Crash data, Performance metrics

13.3 App Permissions

14. MARKETING AND COMMUNICATIONS

14.1 Communication Preferences

You can control how we communicate with you:

Marketing Messages:

• Email: Click "unsubscribe" in any marketing email
• SMS: Reply "STOP" to opt-out
• Push Notifications: Manage in phone settings
• In-App: Settings > Notifications > Marketing

Service Messages: Some communications are essential for service delivery and cannot be opted out of, including:

• Security alerts
• Payment confirmations
• Booking updates
• Legal notices

14.2 WhatsApp Communications

If you opt-in, we may send service updates via WhatsApp in compliance with WhatsApp Business policies.

15. PRIVACY POLICY UPDATES

We may update this Privacy Policy to reflect:

• Changes in our data practices
• New features or services
• Legal or regulatory requirements
• Expansion to new countries

How we'll notify you:

• In-app notification banner
• Email to your registered address
• SMS notification
• 30 days advance notice for material changes

Your choices:

• Continue using Ezzyly (acceptance)
• Contact us with questions
• Export your data
• Delete your account if you disagree

16. FUTURE EXPANSION PROVISIONS

16.1 Planned Expansion

As Ezzyly expands from Nigeria to other countries, this Privacy Policy will be updated to include:

Other African Countries (Planned):

• Compliance with local data protection laws
• Local payment processor integrations
• Country-specific data storage requirements

United States and Europe (Future):

• GDPR compliance for EU operations
• CCPA/CPRA compliance for California
• State privacy law compliance

Global Operations (Future):

• International data transfer agreements
• Multi-jurisdictional compliance framework
• Global privacy standards adoption

16.2 Your Rights Will Expand

As we enter new markets, users in those countries will receive additional privacy rights as required by local law.

17. CONTACT INFORMATION

17.1 Privacy Inquiries

Data Protection Officer:
Email: privacy@seerglobalsolutions.com
Phone: 234-(0)904-949-5759
Response Time: Within 30 days

General Contact:
Seer Global Solutions Limited
Suite B 8, Real Tower Center
Plot 1121 Obafemi Awolowo Way
Utako District
Federal Capital Territory (FCT)
Nigeria

17.2 Other Contacts

17.3 Regulatory Authority

National Information Technology Development Agency (NITDA)
Website: www.nitda.gov.ng
Email: info@nitda.gov.ng
Phone: +234 (0) 92 200 720
For privacy complaints or violations

17.4 Parent Company

Seer Group Inc. (USA)
Parent company of Seer Global Solutions Limited

18. SUMMARY OF KEY POINTS

✅ What We Do

• Protect your data with encryption
• Give you control over your information
• Process data only as described
• Comply with Nigerian privacy laws
• Respect your communication preferences
• Delete data when no longer needed

❌ What We DON'T Do

• Sell your personal information
• Share data without legal basis
• Track you across other apps
• Use data for undisclosed purposes
• Keep data longer than necessary
• Transfer data without safeguards

🎛️ Your Control Panel

• Download Your Data: Settings > Privacy > Download My Data
• Delete Account: Settings > Account > Delete Account
• Update Info: Profile > Edit Profile
• Privacy Settings: Settings > Privacy
• Opt-Out Marketing: Settings > Notifications
• Contact DPO: privacy@seerglobalsolutions.com

19. PHOTO AND VIDEO ACCESS

Ezzyly requests permission to access photos and videos stored on your device for the following purposes:

19.1 Photo Access (READ_MEDIA_IMAGES):

- Profile Management: Upload profile pictures and update your account information
- Service Requests: Attach images to service requests for clear communication with providers
- Identity Verification: Submit identification documents during KYC (Know Your Customer) verification
- Service Documentation: Capture and share before/after photos of completed services
- Provider Credentials: Allow service providers to upload proof of qualifications and certifications

19.2 Video Access (READ_MEDIA_VIDEO):

- Identity Verification: Record a video selfie when entering your National Identification Number (NIN) for KYC verification to confirm your identity and prevent fraudulent accounts
We only access media files that you explicitly select or record through our app. We do not scan, access, or collect photos and videos from your device without your direct action and consent. All uploaded media is transmitted securely using encryption and stored in accordance with Nigerian data protection regulations.
Identity verification videos are processed solely for authentication purposes and are handled with the highest security standards.
You can revoke these permissions at any time through your device's Settings > Apps > Ezzyly > Permissions.

APPENDIX A: GLOSSARY OF TERMS

Personal Data: Any information relating to an identified or identifiable person

Processing: Any operation performed on personal data (collection, storage, use, disclosure)

Data Controller: Entity determining purposes and means of processing (Seer Global Solutions Limited)

Data Processor: Entity processing data on controller's behalf (our service providers)

Data Subject: The person whose data is processed (you)

NDPR: Nigeria Data Protection Regulation 2019

NITDA: National Information Technology Development Agency

BVN: Bank Verification Number

NIN: National Identification Number

DPO: Data Protection Officer

APPENDIX B: QUICK REFERENCE - DATA CATEGORIES

© 2026 Seer Global Solutions Limited. All rights reserved.

Ezzyly[tm] is a trademark of Seer Group Inc.

This Privacy Policy is effective as of January 10, 2026, for users in Nigeria. Policies for other countries will be implemented as we expand our services.