Privacy Policy

1. Introduction

T Crew Limited ("freemoney," "we," "our," or "us"), a company duly incorporated under the laws of the Federal Republic of Nigeria, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and related services (collectively, the "Services").

This Privacy Policy is compliant with the Nigeria Data Protection Act 2023 ("NDPA"), the Cybercrimes (Prohibition, Prevention, etc.) Act 2015, Apple App Store Guidelines (including App Tracking Transparency requirements), and Google Play Store requirements.

Please read this Privacy Policy carefully. By using our Services, you consent to the collection and use of your information as described in this policy. If you do not agree with this policy, please do not use our Services.

2. Information We Collect

2.1 Personal Information You Provide

When you use our Services, we may collect:

• Phone number (for account verification and login)
• Full name and username
• Date of birth and gender
• Profile picture
• Email address (optional)
• Bank account details (for withdrawals)
• Government-issued identification (for KYC verification)
• Content you post, including stories, comments, and messages

2.2 Information Collected Automatically

When you access our Services, we automatically collect:

• Device information (type, model, operating system)
• Unique device identifiers
• IP address and general location
• App usage data and interaction patterns
• Game scores and performance data
• Crash reports and diagnostics
• Push notification tokens

2.3 Information from Third Parties

We may receive information from:

• Analytics providers
• Payment processors
• Marketing partners
• Social media platforms (if you choose to link accounts)
• Identity verification services (for KYC purposes)

3. Lawful Basis for Processing (NDPA Compliance)

In accordance with the Nigeria Data Protection Act 2023, we process your Personal Data only where we have a lawful basis to do so:

• Consent: Where you have given explicit consent for specific processing activities.
• Contract: Where processing is necessary for the performance of our contract with you (i.e., providing the Services).
• Legal Obligation: Where we are required to process data to comply with Nigerian law, including the Cybercrimes Act 2015 and CBN regulations.
• Legitimate Interests: Where processing is necessary for our legitimate interests, provided these do not override your rights and freedoms.
• Vital Interests: Where processing is necessary to protect vital interests of you or another person.

4. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services
• Create and manage your account
• Process game entries and determine winners
• Process withdrawals and payments
• Conduct Know Your Customer (KYC) verification as required by CBN regulations
• Send you notifications about your account and activities
• Provide customer support
• Personalize your experience and content recommendations
• Detect and prevent fraud, abuse, and security incidents
• Comply with legal obligations under Nigerian law
• Analyze usage patterns to improve our Services
• Send promotional communications (with your consent)

5. Sharing of Information

We may share your information in the following circumstances:

5.1 With Service Providers

We share information with third-party vendors who perform services on our behalf, such as:

• Cloud hosting and data storage
• Payment processing
• KYC and identity verification services
• Analytics and crash reporting
• Push notification services
• Customer support tools

5.2 With Other Users

When you post content or interact on our platform, other users may see your:

• Username and profile picture
• Posts, stories, and comments
• Game achievements and leaderboard rankings

5.3 For Legal Reasons

We may disclose information when required by law or to:

• Comply with legal processes and lawful requests from Nigerian authorities
• Respond to requests from the Nigeria Data Protection Commission (NDPC)
• Cooperate with law enforcement under the Cybercrimes Act 2015
• Comply with CBN and NDIC regulatory requirements
• Protect our rights, privacy, safety, or property
• Investigate potential violations of our Terms or EULA

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information in accordance with NDPA requirements, including:

• 256-bit SSL encryption for data in transit
• Encrypted storage for sensitive data
• Regular security assessments and audits
• Access controls and authentication
• Secure development practices
• Employee training on data protection

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security.

7. Data Breach Notification

In accordance with the NDPA 2023, in the event of a personal data breach that is likely to result in high risk to your rights and freedoms, we will:

• Notify the Nigeria Data Protection Commission (NDPC) within 72 hours of becoming aware of the breach
• Notify affected users without undue delay
• Document the breach and our response measures
• Take appropriate steps to mitigate the effects of the breach

8. Data Retention

We retain your personal information for as long as:

• Your account is active
• Necessary to provide our Services
• Required by law (minimum two years for transaction records under the Cybercrimes Act)
• Needed to resolve disputes and enforce agreements
• Required by CBN and financial regulations

When you delete your account, we will delete or anonymize your personal information within 30 days, except where we are required to retain it for legal, regulatory, or compliance purposes.

9. Your Rights Under NDPA 2023

Under the Nigeria Data Protection Act 2023, you have the following rights:

• Right of Access: Request a copy of your personal data we hold
• Right to Rectification: Update or correct inaccurate or incomplete information
• Right to Erasure: Request deletion of your personal data (subject to legal retention requirements)
• Right to Restriction: Request that we restrict processing of your data in certain circumstances
• Right to Object: Object to processing based on legitimate interests or direct marketing
• Right to Data Portability: Receive your data in a structured, commonly used, and machine-readable format
• Right to Withdraw Consent: Withdraw previously given consent at any time
• Right to Lodge Complaints: File a complaint with the Nigeria Data Protection Commission (NDPC)

To exercise these rights, please contact us at privacy@freemoney.ng or use the settings in the App. We will respond to your request within 30 days.

10. Account Deletion

You can request to delete your account at any time through:

• The App settings (Profile → Settings → Delete Account)
• Our website at freemoney.ng/delete-account
• Contacting our support team

Upon deletion request, your account will be deactivated immediately and permanently deleted within 30 days. Any pending withdrawals will be processed before deletion. Note that certain data may be retained as required by Nigerian law and regulations.

11. Children's Privacy

Our Services are not intended for users under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18 without verifiable parental consent, we will delete that information promptly.

If you believe a child under 18 has provided us with personal information, please contact us immediately at privacy@freemoney.ng.

12. International Data Transfers

Your information may be transferred to and processed in countries other than Nigeria. When we transfer data internationally, we ensure that:

• Appropriate safeguards are in place in accordance with NDPA requirements
• Data is transferred only to countries with adequate data protection laws or to recipients who provide appropriate guarantees
• Your rights and protections under Nigerian law are maintained

13. Third-Party Links and Services

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on this page
• Updating the "Last updated" date
• Sending a notification through the App
• Sending an email notification where appropriate

Your continued use of the Services after any changes indicates your acceptance of the updated Privacy Policy. If you do not agree to changes, you must discontinue use of the Services.

15. NDPA 2023 Compliance Statement

freemoney is committed to full compliance with the Nigeria Data Protection Act 2023 and is guided by the following principles:

• Processing Personal Data lawfully, fairly, and transparently
• Collecting data for specified, explicit, and legitimate purposes only
• Ensuring data accuracy and keeping it up to date
• Limiting data collection to what is necessary
• Retaining data only as long as necessary
• Implementing appropriate security measures
• Maintaining accountability for data processing activities
• Respecting and facilitating data subject rights

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will respond to your inquiry within 30 days.

You also have the right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) if you believe your data protection rights have been violated.