Privacy Policy

1. Introduction

Starlinker NG ("we," "us," or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services in compliance with the Nigeria Data Protection Regulation (NDPR) 2019 and other applicable laws.

By using our services, you consent to the data practices described in this policy. If you do not agree with this policy, please do not use our platform.

2. Information We Collect

2.1 Personal Information

We collect the following personal information:

• Account Information: Name, email address, phone number, password
• Profile Information: Profile picture, bio, preferences
• Booking Information: Service bookings, dates, times, locations
• Payment Information: Billing address, payment method details (processed securely through Paystack)
• Delivery Information: Shipping address, delivery preferences
• Communication Data: Customer support messages, chat conversations
• Identity Verification: Government-issued ID (when required for high-value services)

2.2 Automatically Collected Information

• Device Information: IP address, browser type, device type, operating system
• Usage Data: Pages visited, time spent, features used, search queries
• Location Data: Approximate location based on IP address
• Cookies: Session data, preferences, analytics

3. How We Use Your Information

We use your personal information for the following purposes:

• Service Delivery: Process bookings, manage WiFi bypass subscriptions, fulfill shop orders
• Account Management: Create and maintain your account, authenticate users
• Payment Processing: Process transactions, generate invoices, manage refunds
• Customer Support: Respond to inquiries, resolve issues, provide assistance
• Communication: Send order confirmations, service updates, important notices
• Improvements: Analyze usage patterns, improve our services, develop new features
• Security: Detect fraud, prevent abuse, ensure platform security
• Legal Compliance: Comply with Nigerian laws and regulations
• Marketing: Send promotional offers (with your consent, opt-out available)

4. Legal Basis for Processing (NDPR Compliance)

We process your personal data based on:

• Consent: You have given explicit consent for specific processing activities
• Contract Performance: Processing is necessary to fulfill our service agreement with you
• Legal Obligation: We must process data to comply with Nigerian law
• Legitimate Interests: Processing is necessary for our legitimate business interests while respecting your rights

5. Data Sharing and Disclosure

5.1 Third-Party Service Providers

We share data with trusted partners who assist us:

• Payment Processors: Paystack (for secure payment processing)
• Cloud Services: Supabase (for data storage and hosting)
• Delivery Partners: Logistics companies (for shop order delivery)
• Email Services: For sending transactional and marketing emails
• Analytics: To understand how users interact with our platform

5.2 Legal Requirements

We may disclose your information when required by Nigerian law, court order, or government request.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity.

5.4 With Your Consent

We may share data with other parties when you give us explicit permission.

6. Your Rights Under NDPR

As a Nigerian citizen or resident, you have the following rights:

• Right to Access: Request a copy of your personal data we hold
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a machine-readable format
• Right to Object: Object to certain processing activities
• Right to Withdraw Consent: Withdraw consent at any time without affecting prior processing
• Right to Lodge a Complaint: File a complaint with the Nigeria Data Protection Commission (NDPC)

To exercise these rights, contact us at privacy@starlinker.ng

7. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encryption in transit (HTTPS/TLS) and at rest
• Secure authentication and access controls
• Regular security audits and vulnerability assessments
• Employee training on data protection
• Incident response procedures
• Secure data centers with physical security measures

However, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security but will notify you of any breach as required by law.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law.

• Account Data: Retained while your account is active plus 2 years after closure
• Transaction Records: Retained for 6 years (Nigerian tax law requirement)
• Communication Logs: Retained for 1 year
• Analytics Data: Aggregated and anonymized after 2 years

9. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected data from a child, please contact us immediately.

10. International Data Transfers

Your data may be processed outside Nigeria by our service providers. We ensure adequate safeguards are in place through:

• Standard contractual clauses
• Vendor security certifications
• Data processing agreements

11. Cookies and Tracking

We use cookies and similar technologies to:

• Maintain your session and preferences
• Analyze site usage and performance
• Provide personalized content
• Improve security

You can control cookies through your browser settings. Disabling cookies may affect functionality.

12. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes via email or prominent notice on our platform. Continued use after changes constitutes acceptance.

13. Contact Us

For privacy-related questions, concerns, or to exercise your rights:

14. Regulatory Authority

This policy complies with the Nigeria Data Protection Regulation (NDPR) 2019. If you wish to file a complaint: