Privacy Policy

1. Who we are

Agenvia ("we", "us", "the platform") is the data controller for the personal data processed through our services. We are operated by [AGENVIA LEGAL ENTITY NAME], with registered offices at [REGISTERED OFFICE ADDRESS]. You can reach our Data Protection Officer at privacy@agenvia.com. [NDPR FILING NUMBER: PENDING].

2. Data we collect

Account Data: Name, email address, phone number, and country of residence.

Verification Data (Agents): Government-issued ID, business registration records, reference contact details, physical office address, and office photos (for Tier 2).

Communication Data: We store metadata about messages between users and agents for safety and abuse prevention. Message content is encrypted; we do not read it unless a participant flags it for review.

Device Data: IP address, device type, operating system version, app version, and crash logs.

3. How we use your data

We use your information to create and secure your account, perform agent verification, prevent fraud and impersonation, provide customer support, and improve the platform. We also use data to comply with legal obligations, such as tax reporting for agent subscriptions and responding to lawful law enforcement requests.

4. Legal bases for processing

Under the Nigeria Data Protection Regulation (NDPR) and the GDPR, we process data based on: (a) your explicit consent, (b) the performance of our contract with you, (c) our legal obligations, and (d) our legitimate interests in maintaining a safe and secure platform.

5. Sharing your data

We never sell your personal data. We only share it with: (a) verification partners to confirm credentials, (b) third-party payment processors for processing agent subscriptions, (c) law enforcement when required by a valid legal request, and (d) core infrastructure providers (hosting, analytics) who process data under our strict instructions.

6. International transfers

Your data may be processed in countries outside your own where our infrastructure providers operate. Where we transfer data from Nigeria or the EEA to other jurisdictions, we ensure appropriate safeguards (such as Standard Contractual Clauses) are in place to protect your rights.

7. Data retention

We retain account data for as long as your account is active, plus 6 years after closure for legal, tax, and audit purposes. Verification documents are retained for the same 6-year period. Messaging metadata is typically retained for 12 months unless flagged for a trust and safety investigation.

8. Your rights

Depending on your location, you have the right to access, correct, or delete your personal data. You may also have the right to data portability, to object to certain processing, and to withdraw consent. You have the right to lodge a complaint with the Nigeria Data Protection Bureau (NDPB) or your local supervisory authority.

9. Cookies and tracking

We use essential cookies for account security and session management. We also use analytics tools (like Google Analytics) to understand how the platform is used. You can manage your preferences or opt-out through your browser settings or our in-app privacy controls.

10. Children's privacy

Agenvia is not intended for use by persons under 18. We do not knowingly collect personal data from children. If we become aware that a child has provided us with data, we will delete it immediately and close the associated account.

11. Data security

We use industry-standard encryption for data in transit and at rest. We implement strict access controls and conduct regular security audits. In the event of a significant data breach, we are committed to notifying the relevant authorities and affected users as required by law.

12. Changes to this policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material updates will be notified via email or in-app notice at least 14 days before taking effect.

13. Contact

For any privacy-related questions or to exercise your rights, contact us at privacy@agenvia.com or at our physical address: [REGISTERED OFFICE ADDRESS], Attn: [DATA PROTECTION OFFICER NAME].