This Privacy Policy explains how FinasEdge collects, uses, shares and protects your personal data, and the choices and rights you have. It applies to our website, community, memberships, specialist services, events and affiliate programme.
1. Who we are and how to reach us
Jobbifyme (RCN- 8925382) is the data controller for personal data processed through the Services finasedge offers. Our contact for data protection questions is +2349067926710, at gbenga@finasedge.com.
2. The law we follow
We process personal data in line with the Nigeria Data Protection Act 2023 (NDPA) and the regulations, directives and guidance issued by the NDPC. If you use the Services from another country, local data protection laws may also apply to you. [Lawyer to confirm any additional requirements.]
3. Personal data we collect
|
Category |
Examples |
Where it comes from |
|---|---|---|
|
Account and profile |
Name, email, phone number, country, username, password (stored in protected form), profile photo or bio |
You |
|
Membership and payment |
Plan, billing history, payment status, transaction references |
You, and our payment providers |
|
Specialist and learning activity |
Bookings, intake forms, questions you send, session notes, recordings (with consent), event and clinic attendance, course progress |
You, and our specialists |
|
Community content |
Posts, comments, messages, reactions |
You |
|
Affiliate and Chief data |
Referral link or code, referral and commission records, payout bank details (account name, number and bank) |
You, and our systems |
|
Communications |
Support requests, emails, survey answers, feedback |
You |
|
Technical data |
IP address, device and browser type, pages viewed, log data, cookies |
Your device |
|
Preferences |
Marketing choices, notification settings |
You |
We do not store your full card details. Payments are handled by our payment providers.
Sensitive data. We do not ask you for sensitive personal data such as health, religion or political views, and we ask you not to post it in the community. Financial details you choose to share with a specialist are used only to deliver that session. Never share passwords, PINs or one-time codes with anyone, including us. [We do not ask for your BVN or NIN unless a payout provider requires it; confirm.]
4. How and why we use personal data
|
Purpose |
Lawful basis |
|---|---|
|
Create and run your account, deliver your membership and content |
Contract |
|
Take payments, prevent fraud and manage billing |
Contract; legitimate interests; legal obligation |
|
Book and deliver specialist sessions, clinics and events |
Contract |
|
Record sessions and use anonymised content from them |
Consent |
|
Run the affiliate programme, calculate and pay commission |
Contract; legal obligation (tax and accounting records) |
|
Moderate the community and keep it safe |
Legitimate interests |
|
Provide support and send service messages |
Contract; legitimate interests |
|
Send marketing by email, SMS or WhatsApp |
Consent |
|
Analyse use and improve the Services |
Legitimate interests |
|
Comply with the law, respond to regulators and handle disputes |
Legal obligation; legitimate interests |
Where we rely on consent, you can withdraw it at any time. Withdrawal does not affect processing done before then.
5. Referral data and what Chiefs can see
If you join through a referral link, we record who referred you. The referrer can see only what is needed to run the programme: that a sign-up came through their link, [your username or first name], your plan status and commission events. They cannot see your payment details, your contact details unless you share them in the community, or the content of your specialist sessions. Affiliates and Chiefs must not use this information for anything other than the programme.
6. Who we share personal data with
- Service providers who process data for us, such as payment processors [Paystack, Flutterwave or others], hosting and cloud services, email, SMS and WhatsApp tools, video meeting tools, CRM and analytics tools, customer support software, and accounting and legal advisers. They may only use your data to provide services to us.
- Specialists and moderators, who see only the information needed to deliver your session or keep the community safe.
- Authorities and advisers, where the law requires it or we need to protect our rights, including regulators, courts and law enforcement.
- A buyer or successor, if our business is ever merged or sold, with protections for your data.
We do not sell your personal data. We do not give partner companies your data for their own marketing without your consent. If you click through to a partner product, their privacy policy applies to what they collect.
7. Transfers outside Nigeria
Some of our providers store or process data outside Nigeria. We transfer personal data abroad only where the destination provides adequate protection under the NDPA or where we have appropriate safeguards in place, such as contractual commitments from the provider.
8. Recordings
Some sessions, clinics and events may be recorded. We will tell you before a recording starts, and you may choose not to take part in a recorded session or to turn off your camera and microphone where possible. Recordings are kept for [12 months]. Group clinic recordings and questions are used in shared content only in anonymised form or with your permission.
9. Cookies and similar technologies
We use cookies and similar tools that are essential for the site to work, remember your preferences, measure how the Services are used and, if applicable, support marketing. You can manage non-essential cookies through our cookie banner or your browser settings. Blocking some cookies may affect how the site works. [Add a cookie list or link to a cookie notice.]
10. How long we keep personal data
|
Data |
Retention |
|---|---|
|
Account data |
While your account is active, plus [12 months] |
|
Payment and transaction records |
[6 years] for tax and accounting purposes [lawyer to confirm] |
|
Affiliate and commission records |
[6 years] |
|
Support records |
[24 months] |
|
Session recordings |
[12 months] |
|
Marketing preferences |
Until you unsubscribe or withdraw consent |
|
Technical logs |
[12 months] |
After these periods we delete or anonymise the data, unless the law requires us to keep it longer.
11. How we protect your data
We use measures such as encryption in transit, access controls limited to staff who need the data, confidentiality duties, checks on our service providers, backups and regular reviews. No system is completely secure, so please protect your password and tell us if you suspect a problem. If a data breach is likely to put your rights at risk, we will notify the NDPC within the time required by law (currently 72 hours) and tell affected people where required.
12. Your rights
You can ask us to:
- give you access to your personal data and a copy of it;
- correct data that is wrong or incomplete;
- delete your data, where there is no good reason for us to keep it;
- restrict how we use your data in certain cases;
- stop processing your data where you object, including for direct marketing;
- move your data to another service in a common format, where it applies;
- withdraw your consent at any time;
- not be subject to a decision based only on automated processing that significantly affects you (we do not make such decisions).
To use these rights, email [email]. We may ask you to prove your identity, and we aim to reply within [one month]. We may refuse a request that is unfounded, or where we must keep data by law, for example tax records, and we will tell you why. You also have the right to complain to the Nigeria Data Protection Commission.
13. Marketing messages
We send marketing only where you have opted in. You can unsubscribe at any time using the link in a message or by contacting us. We will still send service messages, such as billing and security notices. If you are in a WhatsApp, Telegram or similar group, remember that other members can see what you post and your username or number as the platform allows.
14. Community posts
What you post in the community can be seen by other members [and in some areas, by the public], and can be copied by others. Do not post sensitive personal or financial information. We cannot control what other members do with what you share.
15. Children
The Services are for people aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we will delete it.
16. Links to other sites
Our Services may link to third-party websites and partner products. We are not responsible for their privacy practices, so please read their policies.
17. Changes to this policy
We may update this Privacy Policy from time to time. We will post the new version with its date and give notice of significant changes by email or on the platform.
18. Contact and complaints
For questions or to use your rights, contact Olugbenga at gbenga@finasedge.com.