Privacy Policy

This Policy explains how Splitwi$e collects, uses, shares, stores and protects personal data, and what rights you have over that data.

It is written primarily around the Nigeria Data Protection Act 2023 (NDPA) and the supervision of the Nigeria Data Protection Commission (NDPC). Where other data protection laws apply to you, we will respect the rights they give you.

The data controller is:

• the Splitwi$e operator whose final legal identity is pending publication (registration details pending publication)
• Registered address: registered address pending publication
• Privacy contact: the privacy request option in your account or the Help page
• Data Protection Officer: the privacy contact shown on the Help page once appointed

Final identity and contact details will be published after legal review and before commercial launch.

Account data — name, email address, phone number, password credentials, profile details and account status.

Location data — the coordinates or address you provide or allow, your delivery area, your chosen Split Point and distance calculations. Precise coordinates are used internally for matching and are never displayed to other shoppers.

Shopping data — product links you submit, items, variants, quantities, baskets, pools you join and orders you place.

Payment data — transaction references, amounts, currency, status and timestamps from our third-party payment provider.

Communication data — pool chat messages, support messages and notification records.

Technical data — device and browser information, IP address, session and security logs.

Map data — place lookups and address details returned by Google Maps and Google Places when you search for or confirm a location.

Operational data — collection records, dispute records and audit logs of sensitive actions.

We do not collect or store your full card number, your CVV or your bank PIN. Card details are entered with the payment provider, not with us.

We also do not track your location continuously in the background. Location is captured when you provide it or when you use a feature that needs it.

Location is central to how Splitwi$e works, so we treat it carefully.

• your precise coordinates are used internally for matching, distance and Split Point selection
• other shoppers never see your exact coordinates or your home address
• pool members may see an approximate distance or general area, and the shared Split Point
• you can enter your location manually instead of sharing device location
• you can change or remove a saved location from your profile

Declining device location will limit matching accuracy and may limit which pools we can suggest, but you can still use the platform by setting a location manually.

We use Google Maps and Google Places for address lookup, geocoding, map display and Split Point information. When you use those features, relevant query data is processed by Google under Google's own privacy terms in addition to this Policy.

Where a product-data provider is enabled for a marketplace, product URLs and product identifiers may be sent to that provider so we can retrieve or verify product information. Providers of this kind are not enabled for every marketplace, and the capabilities that are live are listed on the marketplaces page.

Payments are handled by our third-party payment provider. The provider receives the data it needs to process and verify your payment and applies its own privacy terms. We receive only the transaction metadata described above.

• payment processors, to take and verify payments
• marketplaces and sellers, where a purchase requires it
• logistics providers and Split Point hosts, for delivery and collection
• Google, for maps and location services
• cloud hosting, database and email providers that run the platform
• authorised Splitwi$e operators and staff, under confidentiality obligations
• regulators, law enforcement or courts, where we are legally required

We do not sell your personal data.

Other members of a pool can see only:

• your display name
• your avatar, if you set one
• a general area or approximate distance
• messages you post in pool chat

They do not see your exact location, your home address, your email address, your phone number or your payment details.

Some providers we rely on operate outside Nigeria, so your data may be processed abroad. Where that happens we rely on the transfer mechanisms permitted by the NDPA and require appropriate contractual safeguards from those providers.

We keep data for as long as it is needed for the purpose it was collected for, and no longer. We do not keep personal data “forever”.

• account data — while your account is active, then for a limited closure period
• order and transaction records — for the period required by accounting, tax and regulatory rules
• payment metadata — for the period required for financial record-keeping and dispute handling
• location records — while they remain useful for matching and delivery, and are then reduced or deleted
• chat messages — while the pool and any related dispute remain active
• security and audit logs — for a limited period appropriate to security and investigation needs

We have not quoted specific retention periods in years here because those periods are being confirmed with our advisers. They will be stated in a future version rather than invented now.

Under the NDPA 2023 you have the right to:

• access the personal data we hold about you
• have inaccurate data corrected
• have data deleted, where the law allows
• restrict how we process your data
• object to processing based on legitimate interest
• receive your data in a portable format
• withdraw consent at any time, without affecting earlier lawful processing
• complain to the Nigeria Data Protection Commission (NDPC)

To exercise a right, use the privacy request option in your account or the Help page. We will respond within the time the law allows, and we may need to verify your identity first.

We use automated logic to suggest pools, calculate distance, allocate shipping and apply risk checks. These are operational calculations, and a suggestion can be overridden by choosing a different eligible pool.

Where an automated risk check materially affects you — for example by holding a transaction — you can ask for human review through the Help page.

We use strictly necessary cookies and local storage to sign you in, secure your session, remember your consent choice and protect against fraud. These cannot be switched off.

Preference, analytics and marketing categories are optional, and they are switched off until you allow them. Nothing optional is pre-ticked.

Open cookie preferences to review or change your choice at any time.

We protect data with encryption in transit, access controls, row-level database security, server-side verification of sensitive actions, and audit logging.

No online service can promise perfect security, and we do not claim to. We do commit to responding quickly when something goes wrong.

If a personal data breach occurs that is likely to affect your rights, we will notify the NDPC and affected users as required by the NDPA, and describe what happened, what data was involved and what we are doing about it.

Splitwi$e is intended for people aged 18 and over. We do not knowingly collect personal data from children. If we learn that we have, we will delete it. A parent or guardian can use the privacy request option in your account or the Help page about this.

Marketing messages are sent only with your consent, and you can unsubscribe at any time using the link in the message or the preferences in your account. Service messages about your orders, payments and collections are not marketing and will continue while you have an active account.

You can ask us to delete your account through the privacy request option in your account or the Help page.

Some records — particularly transaction, tax and dispute records — must be retained for the period the law requires even after deletion. We will tell you what is being kept and why.

Splitwi$e links to marketplaces and other third-party sites. We do not control those sites and are not responsible for their privacy practices. Read their policies before sharing data with them.

We may update this Policy. Each version has its own version number and effective date, and previous versions are retained so you can see what applied when. We will tell you about material changes.

If you are unhappy with how we handle your data, use the privacy request option in your account or the Help page or contact the privacy contact shown on the Help page once appointed, and we will investigate.

You can also complain to the Nigeria Data Protection Commission (NDPC). Using our process first is not a condition of that right.

• Controller: the Splitwi$e operator whose final legal identity is pending publication
• Registered address: registered address pending publication
• Privacy: the privacy request option in your account or the Help page
• Data Protection Officer: the privacy contact shown on the Help page once appointed
• Support: the Help page