SparoPay Privacy Policy

Vendor Data Retention & Privacy Policy

This policy outlines how SparoPay manages, retains, and deletes data specifically for our Partner Vendors. As a Vendor, your use of the platform involves the processing of commercial transactions, and we are committed to securing that data.

1. Business & Transactional Records

• Order Details: Records of all accepted and processed orders, including item lists and customer delivery notes, are retained for 7 years.
• Financial Transactions: Data regarding payments received, commissions deducted, and payouts to your bank account are retained for 7 years.
• Purpose: This ensures compliance with statutory tax laws and financial auditing requirements in Nigeria. It also provides you with a long-term ledger for your business accounting.

2. KYC and Verification Data

• Identity & Business Documentation: Government-issued IDs, business registration documents (CAC), and bank verification details provided during onboarding are retained for the duration of your partnership.
• Post-Termination Retention: If you close your Vendor account, this data is retained for 5 years.
• Purpose: This is a mandatory safety measure for Anti-Money Laundering (AML) compliance and to prevent fraudulent re-registration of previously banned entities.

3. Store Location & Operational Data

• Store Coordinates: Your fixed business location is stored for the duration of your active status to facilitate rider matching.
• Device Location: If using the Vendor App on a mobile device, location data is used only to verify order handovers and is not tracked once the app is closed.

4. Communication & Support

Merchant Support: All logs of communication between the Vendor and SparoPay support (via chat or email) are kept for 2 years to ensure quality of service and resolve potential future disputes.

5. Vendor Account Deletion & Right to Erasure

We provide a streamlined process for Vendors who wish to cease operations on the SparoPay platform and request the deletion of their data.

How to Request Deletion
To close your Vendor account and initiate data removal:

• Web Request: Visit sparopay.com/delete-account.
• Form Submission: Fill in your registered Business Name and Merchant ID to request account closure.

Rider Location Privacy Policy

This document explains how SparoPay collects, uses, and protects your location data. We are committed to transparency and ensuring you have full control over your personal information.

1. Real-Time Tracking & Usage

SparoPay collects and tracks your precise location data in real-time whenever you are marked as "Online" within the app. This collection is a functional necessity to:

• Job Matching: Identify your position to assign nearby delivery orders and packages.
• Logistics Accuracy: Calculate precise Estimated Times of Arrival (ETA) for both vendors and customers.
• Service Reliability: Ensure the nearest available rider is selected to minimize travel time and fuel consumption.

2. Background and Closed-App Tracking

To maintain a seamless delivery experience, SparoPay collects location data even when the app is closed or running in the background, provided your status is set to "Online."

• Why this is necessary: This allows the system to offer you new delivery opportunities as you move through different zones without requiring you to keep the app open on your screen.
• Live Updates: It provides customers and vendors with continuous, real-time progress updates from pickup to drop-off, which is a core requirement of the SparoPay service.
• Consent: Background tracking only occurs when you have explicitly toggled your status to "Online."

3. Purpose of Data Collection

We use your location data strictly for the following purposes:

• Service Fulfillment: Facilitating the core matching, pickup, and delivery process.
• Safety and Security: Maintaining a digital record of travel to assist in the event of disputes, accidents, or security incidents.
• Customer Transparency: Providing live tracking to users to improve service trust and reduce delivery inquiries.

4. User Control and Data Management

You maintain full control over your data:

• Toggle Tracking: You can stop location tracking instantly by setting your status to "Offline."
• Device Permissions: You can manage or revoke location permissions at any time through your mobile device settings, though this may limit your ability to receive delivery jobs.

5. Account and Data Deletion

SparoPay respects your right to be forgotten. If you wish to close your account and remove your personal data from our systems:

• How to Delete: Please visit sparopay.com/delete-account.
• The Process: Once on the page, fill out the account deletion request form.
• Data Handling: Upon receiving your request, we will initiate the process of permanently deleting your profile and associated location history, subject to any legal or regulatory record-keeping requirements (such as completed financial transaction records).

DATA PRIVACY AND POLICY FOR SPAROPAY MULTIPURPOSE SERVICES LTD

1. INTRODUCTION

Sparopay Multipurpose Service LTD ("Sparopay", "We", "Us", "Our") is an integrated service marketplace that connects consumers with verified Vendors and service providers. We are committed to respecting your privacy and protecting your Personal data. In this sense, the aim of this Privacy Policy is to inform you about our processing activities.

At Sparopay, one of our core values is transparency and we owe you ('User') a duty to tell you how we collect, use and share your personal information. Personal information means information that identifies you and includes information such as your name, email address, telephone number as well as any other personal data collected. We recommend that you read this Privacy Policy ("Policy") carefully to understand your rights and our duties towards managing your personal data in addition to our Terms of Use. If you have any questions about either of these documents, please send us an email at contact@sparopay.com.

2. UPDATE OF POLICY

Due to the constant evolution of Sparopay's activities, this Privacy Policy will be reviewed annually to ensure compliance with applicable data protection laws and regulations in all jurisdictions where the Services are provided, including but not limited to the Nigeria Data Protection Act (NDPA), 2023. If and when our data protection practices change, we will update this Policy to describe our new practices and publish them on our website and applications.

3. CONSENT

You accept this Policy when you click on the "continue" button to sign up and use any of our Platforms, products and Services. You also consent to the collection and processing of your personal information (which includes but is not limited to your name, date of birth, email address, address, telephone number, etc), your order details, order history and any other information for the purpose of providing the Services. If you decide to opt out of any of the Services or withdraw consent for the processing of your personal information, you can do so by reaching out to us at contact@sparopay.com.

This Policy governs the use of the Sparopay Services and if you are not comfortable with us processing your data, you may not use our Services.

4. DATA COLLECTION AND USAGE

We can get your personal information when you:

• Buy a product or service from us.
• Register for a specific product or service (such as registering your name, phone number, email address and physical address details for any of our services).
• Subscribe to newsletters or other services from us.
• Ask us for more information about a product or service or contact us with a question or complaint.
• Take part in a promo or survey.
• Use our website and other services.
• Visit or browse our website or other platforms.
• With your permission or consent and/or as permitted by law, we may also collect information about you from other organizations or third parties if this is appropriate and allowed by law. These include fraud-prevention agencies, business directories, and credit reference agencies.

4.1 Data Collected

a. Registration Data: the information provided by you when you create an account on Our Platform: username and e-mail.

b. User Profile Information: the information added by you on the Platform in order to be able to use our services... We may collect other information from Vendors, Riders and Mandataries, such as your business name, business address, business identification/registration number, vehicle type.

c. Payment information: payment information when processing your orders; card data will be processed by our electronic payment service providers.

d. Data on the application and the device: Sparopay collects and stores data on the device and the Application used by you to access our services (IP address, operating system, URL Clickstream, Contacts for airtime gifting, browsing history).

e. Cookies usage: We might use cookies to record your details so we can recognise you if you visit our website again.

f. Geolocation Data: provided that you have authorised this, Sparopay will collect data relating to your location.

g. Data resulting from external third parties: collected only if you authorise such third parties (e.g., Google/Facebook) to share that information with Sparopay.

h. Package delivery data: Sparopay will collect package descriptions, size, type, images pickup and drop-off coordinates and street addresses.

i. Communication: Sparopay will record all communications received through our Platform for safety, monitoring and quality assurance purposes.

4.2 Data Usage

When you are a User/Vendor/Mandatary we may use and analyse your data for:

• Providing the Services and facilitating the listing of Vendors/Mandataries around you.
• Complying with all applicable laws and regulations.
• Preventing and detecting fraud and illegal activities.
• Providing customer support services, including responding to enquiries or complaints.
• Processing and facilitating payment for services provided on our platform.
• Communication: sending transaction alerts, OTPs (via SMS, Termii), and delivery updates (via Email, SMS).

The lawful basis for processing your data is the performance of our contractual obligation to you.

5. THIRD-PARTY DATA SHARING

When carrying out your order, your data may be shared with:

• The Courier who carries out the task of collecting and delivering the product.
• The Vendor in charge of selling the product.
• The payment Platform and payment service providers.
• Telecommunications service providers.

6. SECURITY AND STORAGE

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, disclosure, or alteration and unauthorised access. Personal information and associated data stored on servers are encrypted and stored through proper data technology.

6.1 Security

6.1.1 Authentication and access control:

• JWT: stateless authentication using JSON Web Tokens.
• Rate Limiting: Login (Lockout strategy after 5 failed attempts), Wallet PIN blocked for 1 hour after failed attempts.
• Role-based Access: strict separation between User, Vendor, Rider, and Admin scopes.

6.1.2 Network Security:

• Transport: all API communication is over HTTPS.
• GraphQL: Custom error interception handles authentication errors gracefully.
• Webhooks: KoraPay webhooks are verified using HMAC signatures to prevent spoofing.

6.2 Storage

Sparopay shall retain your data for the duration of the contractual relationship and, after this has come to an end, for the period established by law.

7. USER RIGHTS AND CONTACT

Users have the right to access, correct, amend, and delete personal information or object to processing your personal information.

You may make any of the following requests:

• Confirmation on the personal information we hold about you.
• Access to the personal information we hold about you.
• Correction of or updates to the personal information.
• Deletion or erasure of personal information via Sparopay's delete account feature.

Users can also delete their accounts from the Sparopay application via sparopay.com/delete-account.

8. MARKETING

We may occasionally contact you directly with related point-to-point restaurant information and special offers from us and other Vendors. You may click the "Unsubscribe" button if you decide you do not wish to receive marketing communications.

9. DISCLAIMER

Sparopay has no prior relationship or representation with the Vendors whose services are listed on Sparopay's Platform. Sparopay will not be responsible for any breach in the representations made by the Vendor.

10. GOVERNING LAW

This Policy is/shall be governed by the laws of the Federal Republic of Nigeria.