Privacy Policy

1. Introduction

This Privacy Policy explains how Secy Worldwide Limited (Nigeria) Limited, trading as "Secygo" ("Secygo", "Company", "we", "our", or "us"), collects, uses, stores, discloses, transfers, and otherwise processes personal data in connection with our transportation, ride-hailing, logistics, courier, dispatch, delivery, mobility, payment, customer support, and related services. Secygo is committed to protecting the privacy, confidentiality, integrity, and security of personal data in accordance with:

• The Constitution of the Federal Republic of Nigeria 1999 (as amended), particularly Section 37;
• The Nigeria Data Protection Act, 2023 ("NDPA");
• Directives, Regulations, Guidelines and Codes issued by the Nigeria Data Protection Commission ("NDPC");
• The Federal Competition and Consumer Protection Act, 2018;
• The Cybercrimes (Prohibition, Prevention, Etc.) Act, 2015;
• The Evidence Act, 2011;
• Applicable telecommunications, financial services, transportation, consumer protection, and electronic commerce laws.

2. Data Controller

For purposes of the NDPA, Secygo acts as a Data Controller and, where applicable, a Data Processor. Company Name: Secy Worldwide Limited (Nigeria) Limited Registered Address: No. 16, Bade Oyeleye Street, Diamond Estate, Command, Lagos, Lagos State, Nigeria Email: secy247@secy247.com Telephone: +1 (857) 274-2640

3. Interpretation

Terms used in this Policy shall have the meanings assigned to them under the Nigeria Data Protection Act, 2023. "Personal Data" means any information relating to an identified or identifiable natural person. "Sensitive Personal Data" includes biometric information, health information, genetic data, religious beliefs, ethnic origin, and any category recognized under the NDPA.

4. Categories of Personal Data We Collect

5. Legal Basis for Processing

In accordance with the NDPA, we process personal data based on one or more lawful grounds including:

6. Purposes of Processing

We process personal data to:

• Create and manage accounts
• Facilitate rides and deliveries
• Verify identity
• Process payments
• Provide customer support
• Prevent fraud and abuse
• Ensure user safety
• Monitor platform performance
• Conduct audits
• Comply with legal obligations
• Improve products and services
• Conduct analytics and research
• Communicate updates and notifications
• Resolve disputes

7. Automated Decision-Making

Secygo may use automated systems for:

• Matching riders and drivers,
• Fraud detection,
• Safety risk analysis,
• Pricing calculations,
• Route optimization

Where required by law, affected individuals may request human review of significant automated decisions.

8. Location Data

Location data is essential for operation of transportation and delivery services. Users may disable location services through device settings; however, certain services may become unavailable.

9. Payment Information

Payment transactions may be processed through third-party payment service providers. Secygo does not intentionally store complete payment card details except where permitted by law and industry standards. Payment processors are independently responsible for compliance with applicable financial regulations.

10. Disclosure of Personal Data

We may disclose personal data to :

11. International Data Transfers

Personal data may be transferred outside Nigeria where necessary. Such transfers shall occur only where:

• Adequate safeguards exist;
• Binding contractual protections are implemented;
• The transfer complies with the NDPA and NDPC requirements;

12. Data Retention

We retain personal data only for as long as necessary to: When no longer required, data shall be securely deleted, anonymized, or archived.

• Fulfil contractual obligations;
• Comply with legal requirements;
• Resolve disputes;
• nforce agreements;
• Protect legal rights;

13. Security Measures

Secygo implements appropriate technical and organizational measures including:

• Encryption
• Access controls
• Authentication systems
• Security monitoring
• Network protection
• Incident response mechanisms
• Employee confidentiality obligations

No system is completely secure; however, we maintain commercially reasonable safeguards.

14. Data Subject Rights

15. Children's Privacy

Secygo services are not intended for persons below the age of eighteen (18) years unless expressly permitted under applicable law and subject to parental or guardian authorization where required. We do not knowingly collect personal data from children without lawful basis.