Jonify Platform Privacy Policy

1. DEFINITIONS

• “Personal Data”: Any information relating to an identified or identifiable individual.
• “Data Subject”: A user of the Platform whose personal data is processed.
• “Processing”: Any operation performed on personal data (collection storage, use, disclosure, etc.).
• “Controller”: Jonify Technologies Limited.
• “Processor”: Any third-party processing data on our behalf.

2. SCOPE OF THIS POLICY

This Policy applies to:

• Users of the Jonify mobile applications
• Users interacting with the Platform (orders, chat, payments)
• Communications via the Platform
• All data collected through system operations

3. PERSONAL DATA WE COLLECT

4. PURPOSES OF PROCESSING

We process personal data strictly for the following purposes:

• Account creation and management
• Order processing and lifecycle management
• Communication between users and administrators (chat functionality)
• Payment processing and verification
• Platform analytics and performance monitoring
• Fraud detection and security enforcement
• Compliance with legal and regulatory obligations
• Customer support and dispute resolution

5. LAWFUL BASIS FOR PROCESSING (NDPA COMPLIANCE)

We rely on the following lawful bases:

• Contractual Necessity – to provide requested services
• Legal Obligation – Compliance with applicable laws
• Legitimate Interest – system security, fraud prevention, service improvement
• Consent – for marketing communications and non-essential data collection.

6. SECURITY

We use industry-standard encryption to protect your data during transmission. Paystack is PCI-DSS Level 1 certified, ensuring the highest level of security for your payments.

7. DATA SHARING AND DISCLOSURE

We may share personal data with:

All third parties are bound by strict data protection obligations and are prohibited from using your data for marketing or any purpose other than fulfillment.

8. CROSS-BORDER DATA TRANSFERS

Where personal data is transferred outside Nigeria:

• Transfers are made only to jurisdictions with adequate data protection standards, or
• Appropriate safeguards are implemented, including:

• Data Processing Agreement (DPAs)
• Standard contractual clauses
• Encryption and access controls

Since your goods are sourced from China, your order information will be transferred to and processed by suppliers and logistics partners in China. We ensure we utilize Standard Contractual Clauses approved by the NDPC to ensure your data receives the same level of protection as it would within Nigeria.

9. DATA RETENTION

We retain personal data only for as long as necessary:

• Active user accounts → retained during use
• Transaction data → retained for at least 6 years to comply with legal, tax and audit obligations
• Inactive accounts → deleted or anonymized when there is no ongoing legitimate business need to process your personal information

Retention period are determined based on:

• Legal requirements
• Operational necessity
• Dispute resolution needs

10. COOKIES

To enable our systems to recognize your browser or device and to provide and improve our services, we or our authorized service providers may use cookies, beacons and/or other similar technologies (collectively, “Cookies”). For more information about the types of Cookies we use, why, and how you can control them, please read our Cookies Policy.

User may manage cookie preferences through device settings.

11. MARKETING AND COMMUNICATIONS

We may use your Personal Data to send you updates, newsletters, and promotional materials. However, we respect your preferences:

• Email Marketing: You can opt out of receiving marketing emails at any time by clicking the “unsubscribe” link provided at the bottom of our emails.
• Push Notifications: You can manage or disable push notification through your mobile device’s system settings at any time.
• Platform Settings: Where available, you may also manage your communication preferences directly within your account settings on the Platform.
• Direct Request: You may also contact us at privacy@jonifyapp.com to request removal from our marketing lists.
• Note: Even if you opt out of marketing, we will still send you transactional messages (e.g., order confirmations, security alerts, and updates to our Terms) as these are necessary for the performance of our contract with you.

12. DATA SUBJECT RIGHTS (NDPA RIGHTS)

User have the right to:

• Access their personal data
• Request correction of inaccurate data
• Request deletion (“right to erasure”)
• Restrict or object to processing
• Request data portability
• Withdraw consent (where applicable)
• Opt out of marketing communication (see Section 11 for specific opt-out instructions).
• Lodge a Complaint with the Nigeria Data Protection Commission (NDPC) if you believe your right are violated.

To exercise your right, please submit a Data Subject Access Request (DSAR) to support@jonifyapp.com. We will verify your identity before processing the request and respond within 30 days.

13. AUTOMATED DECISION-MAKING

Jonify does not make legally significant decisions based solely on automated processing. System automation (e.g., order status updates, expiry rules) does not materially affect user rights.

14. DATA SECURITY

For registered users of the Jonify Platform, certain personal information and account details may be accessed, updated, or managed through your user account, which is protected by login credentials selected by you. You are solely responsible for maintaining the confidentiality and security of your account credentials, including your password and any authentication codes associated with your account.

You must not disclose your password or account access details to any third party. Jonify will never request your password through unsolicited phone calls, messages, or emails. Where you access the Platform using a shared or public device, you are advised not to save your login credentials on such device and to log out of your account immediately after each session.

The Company implements reasonable and appropriate technical, administrative, and organizational safeguards designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. Such measures may include encrypted communications, secured cloud infrastructure, access controls, monitoring systems, and authentication protocols.

However, notwithstanding these safeguards, no method of transmission over the internet, mobile networks, or electronic storage systems can be guaranteed to be completely secure or free from risk. Accordingly, while Jonify takes commercially reasonable steps to protect your personal data, the Company cannot guarantee the absolute security of information transmitted to or through the Platform, and any transmission of data is undertaken at your own risk.

15. CHILDREN’S DATA

The Platform is not intended for individuals under 18 years.

We do not knowingly collect data from minors as we do not intend to sell any of our product or services to Minors. If a Minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact privacy@jonifyapp.com to remove the information

16. THIRD-PARTY SERVICES

The Platform integrates third-party services (e.g., payment gateways (PAYSTACK), cloud storage). Jonify is not responsible for the privacy practices of such third parties. Users are advised to review their policies.

We share necessary information with specific partners to complete your orders:

• Payment Processing: Paystack handles all financial transactions securely
• Logistics & Shipping: Your name and delivery address are shared with shipping lines and clearing agents involved in transporting goods from China to Nigeria.
• Regulatory Bodies: We share data with the Nigeria Customs Service and other agencies are required by law for cargo clearance.

17. DATA ETHICS & PRIVACY BY DESIGN

We implement Privacy by Design and Privacy by Default, ensuring that protection is integrated into our Platform’s development from the onset.

18. DATA BREACH MANAGEMENT

In the event of a data breach:

• We will take immediate containment measures
• Notify affected users where required
• Report to the Nigeria Data Protection Commission (NDPC) where applicable within the 72-hours.

19. CHANGES TO THIS PRIVACY POLICY

Jonify reserves the right to amend, revise, or update this Privacy Policy from time to time to reflect changes in applicable laws, regulatory requirements, technological developments, operational practices, or the functionality of the Platform.

Where material changes are made to this Privacy Policy, the Company shall take reasonable and appropriate steps to notify users in a manner consistent with the nature and significance of such changes. Such notification may be provided through in-app notifications, email communications, website notices, or other appropriate means.

Where required by applicable law, including the Nigeria Data Protection Act 2023 (NDPA), Jonify shall obtain user consent before implementing any material change that substantially affects previously collected personal data or materially reduces the level of protection afforded to such data.

Any revised version of this Privacy Policy shall become effective upon publication on the Platform unless otherwise stated. Users are encouraged to periodically review this Privacy Policy to remain informed about how their personal data is collected, used, stored, and protected.

The “Last Updated” date appearing at the top of this Privacy Policy indicates the date on which the most recent revisions were made.

20. CONTACT AND DATA PROTECTION OFFICER

Data Protection Enquiries

Attention: Data Protection Officer (DPO)

Address: 75b Ogunnsi Road, Berger, Lagos
Email: privacy@jonifyapp.com
Phone: 08175078921

21. GOVERNING LAW

This Policy shall be governed by the laws of the Federal Republic of Nigeria.