Plugr

Plugr uses your personal information for the following purposes:

• •Account Creation and Management: To register, authenticate, and manage your Plugr account.
• •Identity Verification: To verify the identity of Plugs using government-issued NIN.
• •Service Matching: To connect Clients with verified Plugs based on location, trade, and availability.
• •WhatsApp Communication: To send service notifications, onboarding flows, job updates, and support messages.
• •Payment Processing: To facilitate secure transactions between Clients and Plugs.
• •Platform Safety: To detect fraud, abuse, and policy violations.
• •Customer Support: To respond to inquiries and resolve disputes.
• •Analytics and Improvement: To understand usage patterns and improve our services.
• •Legal Compliance: To comply with applicable Nigerian laws and regulations.
• •Marketing (with consent): To send promotional communications about Plugr features and offers.

We process your personal data under the following legal bases in accordance with the Nigeria Data Protection Act (NDPA) 2023:

• •Contractual Necessity: Processing required to provide the services you have requested.
• •Legitimate Interests: Processing necessary for fraud prevention, platform security, and service improvement.
• •Legal Obligation: Processing required to comply with applicable Nigerian laws.
• •Consent: Processing based on your explicit consent, which you may withdraw at any time.

• •Active Account Data: Retained for the duration of your account and for 2 years after closure.
• •Transaction Records: Retained for 7 years in compliance with Nigerian financial regulations.
• •NIN Verification Records: Retained for the period required by NIMC guidelines.
• •Communication Logs: Retained for 1 year for dispute resolution and safety purposes.
• •Marketing Data: Retained until you withdraw consent or request deletion.

When data is no longer required, we securely delete or anonymise it in accordance with industry best practices.

• •Encryption in Transit: All data transmitted is encrypted using TLS 1.3.
• •Encryption at Rest: Sensitive data stored in our databases is encrypted at rest.
• •WhatsApp Flow Encryption: All data exchanged through WhatsApp Flows is end-to-end encrypted using RSA-2048 and AES-128.
• •Access Controls: Role-based access controls limit data access to authorised personnel only.
• •Authentication: JWT-based authentication with token refresh mechanisms.
• •Rate Limiting: API rate limiting to prevent abuse and brute-force attacks.
• •Regular Audits: Periodic security assessments and vulnerability testing.

Under the Nigeria Data Protection Act (NDPA) 2023, you have the following rights:

• •Right of Access: Request a copy of the personal data we hold about you.
• •Right to Rectification: Request correction of inaccurate or incomplete data.
• •Right to Erasure: Request deletion of your data where we have no legitimate reason to continue processing it.
• •Right to Restriction: Request that we restrict processing in certain circumstances.
• •Right to Data Portability: Receive your data in a structured, machine-readable format.
• •Right to Object: Object to processing based on legitimate interests or for marketing purposes.
• •Right to Withdraw Consent: Withdraw consent at any time where processing is consent-based.
• •Right to Lodge a Complaint: File a complaint with the Nigeria Data Protection Commission (NDPC).

To exercise any of these rights, contact us at privacy@getplugr.com. We will respond within 30 days.

• •Your WhatsApp phone number and messages are processed by Meta in accordance with their Privacy Policy.
• •Data submitted through WhatsApp Flows is encrypted and transmitted securely to Plugr servers.
• •We do not share your WhatsApp data with third parties beyond what is necessary to provide the service.
• •You can opt out of WhatsApp communications at any time by replying STOP to any Plugr message.

Plugr is not responsible for the privacy practices of third-party platforms. We encourage you to review the privacy policies of Meta, Paystack, and other service providers you interact with.

Plugr services are intended for individuals who are 18 years of age or older. We do not knowingly collect personal information from minors under the age of 18.

If you believe we have inadvertently collected information from a minor, please contact us immediately at privacy@getplugr.com and we will delete such information promptly.

• •Essential Cookies: Required for the platform to function correctly (authentication, session management).
• •Analytics Cookies: Help us understand how users interact with our platform.
• •Preference Cookies: Remember your settings and preferences.

You can control cookies through your browser settings. We do not use cookies for cross-site advertising or tracking.

Plugr is incorporated in Nigeria and primarily processes data within Nigeria. However, some third-party providers may process data outside Nigeria, including in the United States and EU.

Where data is transferred internationally, we ensure appropriate safeguards are in place in accordance with the NDPA 2023.

• •We will update the Effective Date at the top of this document.
• •We will notify registered users via email or WhatsApp message.
• •For material changes, we may request renewed consent where required by law.

Your continued use of the Plugr platform after the effective date constitutes acceptance of the updated policy.