1. Introduction/Scope

Welcome to Spraay, a mobile application developed by Middl Technologies. This document is prepared in accordance with the provisions of the Nigeria Data Protection Act (NDPA), It sets out how Spraay App applies and complies with the data privacy principles in processing the personal data of customers, staff, visitors, and any third parties that we interact with.

For personal data of individuals, this document also highlights their rights and covers the data subject(s) whose personal data is collected and processed, in compliance with data protection laws.

This privacy policy describes why and how we collect and use personal information about our data subjects. It also highlights with whom we might share Personal Information and how long we keep such information. It also makes data subjects aware of their rights under the regulation.

2. Policy Statement

Spraay App is committed to protecting the privacy and security of our personal data. We are responsible for determining how we hold and use personal information about our data subjects. According to the Nigeria Data Protection Act (NDPA), Spraay App is required to notify data subjects of the information contained in this document. Spraay App's Data Protection Officer (DPO) is responsible for ensuring that this document is correct and up-to-date.

3. About Spraay App

The Spraay Application is a groundbreaking digital platform that seeks to redefine the way we celebrate, connect, and express appreciation in the digital age. Our mission is to address the evolving dynamics of social gifting, event participation, and financial transactions in a way that transcends existing platforms and embraces the true spirit of celebration.

Spraay centralizes and simplifies services like planning event invitations and RSVP functions, digital money spraying and gifting, bill payments, and convenience services, and gives you access to a user- centric digital wallet. Users can easily manage bill payments, purchase mobile recharge cards, book flights, fund betting accounts, and acquire event tickets on our one-stop platform. This comprehensive approach streamlines financial transactions, offering a more efficient and convenient experience.

4. What information do we need?

Spraay App will be known as the “controller” and “processor” of the personal data you provide to us. We will only collect personal data from you required to efficiently conduct our services; Name, email address, phone number, date of birth, Bank account Information, and Bank Verification Number (BVN).

We will NEVER ask for personal banking information such as card details (CVV); PIN, Password or Token number.

5. What do we do with the information collected?

To enable us to carry out our operational services, we will be required to collect, store, and process some of your personal data. Your consent will be required to execute Spraay App services which include Bill payments, Event invitations, digital money spraying, gifting, and RSVP functions available to you in accordance with the law/regulation in force.

6. How long do we keep it?

We will retain your personal data for ten (10) years or as may be required by regulation in the country under consideration, after which it will be disposed of as required under the respective Government laws.

7. Who Will We Share Your Personal Data With?

Your personal data may be stored in a database that we can access to provide you with our services. We may share your personal data with API providers and banking partners (WEMA BANK) in accordance with NDPR/NDPA requirements.

8. What Are Your Rights?

At any point, while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing
• Right of portability – you have the right to have the data we hold about you transferred to another organisation
• Right to object – you have the right to object to certain types of processing such as direct marketing
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling
• Right to judicial review - if Spraay App refuses your request under rights of access, we will provide you with a reason for the refusal.

9. Legal Basis for Collecting Personal Data

• The Consent of the Data Subject.
• Offer of employment to the Data Subject through the performance of a contract.
• Compliance with Legal obligation.
• Necessary to protect the vital interests of a person in line with Data Privacy regulations.
• Necessary for the performance of a task carried out in the public interest.

10. How to Contact Us?

If you have any feedback or issues about your personal data, or about this Policy, or wish to make a complaint to us, you may contact us by:

Data protection officer: DPO Contact information

Company/Support Email: support@spraayapp.ng

11. Cookies on our Website

We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). We have also grouped our cookies into the following categories, to make it easier for you to understand why we need them:

• Functionality: These cookies enable the technical performance of our websites and allow us to 'remember' the choices you make and your preferences.
• Performance/Analytical: these cookies allow us to collect certain information about how you navigate the Sites. They help us to understand which parts of our websites are interesting to you and which are not as well as what we can do to improve them.

12. Changes to Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website .www.spraay.ng.