This Privacy Policy sets out how NGN Market collects, uses, discloses, and protects personal information in connection with your use of our platform and Services. We are committed to handling your personal information responsibly and in accordance with applicable data protection and privacy laws.

NGN Market is the data controller in respect of personal information processed under this Policy. If you have questions about how we handle your data, you may contact us through the platform or via the channels listed in Section 14.

1. Information We Collect

We collect personal information in three ways: information you provide to us directly, information generated through your use of the Services, and information received from third parties in connection with the Services.

Information you provide directly includes account registration details, communications with us, and any content you create or submit through the platform. Information generated through use of the Services includes activity data, technical identifiers, and interaction records that arise from your use of the platform. Where you subscribe to a paid plan, billing-related information is also processed, though full payment card details are handled exclusively by our payment processor and are not stored on our systems.

We collect only the personal information that is necessary for the purposes described in this Policy.

2. Legal Basis for Processing

We process personal information on one or more of the following bases:

• Performance of a contract: processing necessary to create and manage your account, deliver the Services you have requested, and fulfil our obligations under our Terms of Service.
• Legitimate interests: processing necessary for our legitimate business interests, including improving the platform, preventing fraud and abuse, ensuring platform security, and understanding how our Services are used. We have assessed that these interests are not overridden by your rights and interests.
• Consent: for non-essential communications such as our newsletter and marketing updates, and for non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Legal obligation: where processing is required to comply with a legal obligation to which we are subject, including applicable financial record-keeping requirements.

3. How We Use Your Information

We use the personal information we collect to:

• Create and manage your account and Subscription
• Provide, operate, maintain, and improve the Services
• Process payments and manage billing
• Send transactional communications relating to your account
• Respond to support requests and enquiries
• Monitor usage patterns and platform performance for product improvement
• Detect, investigate, and prevent fraudulent or abusive activity
• Comply with our legal and regulatory obligations
• Send marketing and newsletter communications where you have consented to receive them

We do not use your personal information for purposes that are incompatible with the purposes for which it was originally collected without your consent or as otherwise permitted by applicable law.

4. AI Features

Our AI-powered assistant processes your queries to generate market insights and analysis. Queries submitted to AI features are processed in order to produce responses, and we may use aggregated and anonymised interaction data to improve the quality and relevance of AI outputs over time.

AI processing involves transmission of query data to third-party AI infrastructure, as described in Section 5 below. We recommend that you do not submit sensitive personal, financial, or confidential information in AI chat sessions.

Our AI features do not make automated decisions that produce legal or similarly significant effects on you. All outputs are informational and require human judgement before action is taken.

5. Disclosure of Information

We do not sell, rent, or trade your personal information to third parties. We may disclose personal information in the following circumstances:

• Service providers: we engage trusted third-party providers to assist with operating the platform, including cloud infrastructure, payment processing, email delivery, analytics, AI infrastructure, and error monitoring. These providers are authorised to process your data only as necessary to perform their services and are bound by confidentiality and data protection obligations.
• Legal obligations: where disclosure is required by law, court order, or the lawful request of a Nigerian regulatory authority, including NITDA or the Securities and Exchange Commission.
• Protection of rights: where disclosure is necessary to protect the rights, property, or safety of NGN Market, our users, or the public.
• Business transfers: in connection with a merger, acquisition, restructuring, or sale of assets, your information may be transferred to a successor entity. We will notify you before your information becomes subject to a different privacy policy.
• With your consent: in any other circumstance where you have expressly authorised disclosure.

6. International Data Transfers

Some of our service providers are located outside Nigeria, which means your personal information may be transferred to and processed in other jurisdictions, including the United States and the European Union. When we transfer personal information internationally, we take steps to ensure that it is afforded a reasonable level of protection, including by:

• Using providers that have entered into data processing agreements incorporating appropriate contractual safeguards
• Transferring data only to providers in jurisdictions that have been assessed to provide adequate data protection

7. Data Security

We implement appropriate technical and organisational measures designed to protect your personal information against unauthorised access, disclosure, alteration, or destruction. Access to personal information within our organisation is limited to personnel who require it for legitimate business purposes.

No system of data transmission or storage is entirely secure. While we take our security obligations seriously, we cannot guarantee the absolute security of your information. You should take care to protect your account credentials and notify us immediately if you suspect any unauthorised activity.

8. Data Retention

We retain personal information for as long as your account is active and for a reasonable period thereafter to fulfil the purposes described in this Policy, to resolve disputes, enforce our agreements, and comply with our legal obligations.

When personal information is no longer required, we will delete it or render it anonymous. Where deletion is not immediately possible due to technical constraints, we will isolate your data from further processing until deletion can be completed. You may request deletion of your account and associated personal data at any time by contacting us.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enable the platform to function, to remember your preferences, and to understand how the Services are used. Cookies fall into two broad categories:

• Essential cookies are necessary for the platform to operate and cannot be disabled without significantly affecting your experience. No consent is required for these cookies as they are strictly necessary for the service you have requested.
• Non-essential cookies (including analytics and functional cookies) are used to improve the platform experience and understand usage patterns. These cookies are set only with your consent, which we obtain via our cookie consent mechanism on your first visit.

You may withdraw consent for non-essential cookies at any time by adjusting your preferences through our cookie settings or your browser settings. Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal.

10. Newsletter and Marketing Communications

We send market updates and newsletters only to users who have expressly opted in to receive them. Our legal basis for sending marketing communications is your consent.

You may withdraw your consent and unsubscribe from marketing communications at any time by clicking the unsubscribe link in any marketing email or by contacting us. Opting out of marketing communications will not affect transactional emails related to your account, such as billing notifications and security alerts. We do not share your contact details with third-party marketers.

11. Your Rights

Depending on your location and applicable law, you may have the following rights in relation to your personal information:

• Right of access: you may request a copy of the personal information we hold about you.
• Right to rectification: you may request correction of inaccurate or incomplete personal information.
• Right to erasure: you may request deletion of your personal information, subject to our legal retention obligations.
• Right to data portability: you may request that we provide your personal information in a structured, commonly used, and machine-readable format.
• Right to object: you may object to processing based on legitimate interests, including processing for direct marketing purposes.
• Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
• Right to restrict processing: you may request that we limit the processing of your personal information in certain circumstances.

To exercise any of these rights, please contact us through the platform. We will respond to your request within 30 days. We may ask you to verify your identity before acting on a request.

If you believe your privacy rights have not been respected, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

12. Data Breach Notification

In the event of a security incident affecting your personal information, we will notify affected users promptly and take appropriate steps to contain and remediate the issue. Where required by applicable law, we will also notify the relevant regulatory authority. Our notification will describe the nature of the incident, the information affected, and the steps we are taking to address it.

13. Children's Privacy

The Services are not directed to individuals under the age of 18. We do not knowingly collect or process personal information from minors. If you believe that a minor has provided us with their personal information, please contact us and we will take prompt steps to delete that information.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our Services, or applicable law. Where changes are material, we will provide notice via email or a prominent notice on the platform before the changes take effect. The "Last updated" date at the top of this page reflects the date of the most recent revision.

15. Contact Us

For questions about this Privacy Policy, to exercise your data rights, or to raise a privacy concern, please contact us through the platform or reach us on Twitter or LinkedIn.