Nigeria Privacy Policy

Introduction

DolRise is a social platform designed with respect for individual privacy, personal dignity, and emotional well-being. This Nigeria Privacy Policy explains how DolRise collects, uses, stores, and protects personal data relating to users located in the Federal Republic of Nigeria, in accordance with the Nigeria Data Protection Act (NDPA) 2023 and other applicable laws.

This policy is intended to provide clear and transparent information to users in Nigeria regarding the types of personal data processed by DolRise, the purposes for which such data is processed, and the rights available to individuals as data subjects under Nigerian law. DolRise treats data protection as both a legal obligation and an ethical responsibility.

DolRise operates on the principle of data minimisation. Personal data is collected only where necessary to provide platform services, maintain security, comply with legal obligations, and support lawful monetisation features. DolRise does not collect or retain personal data beyond what is reasonably required for these purposes.

Certain automated systems may be used to improve the user experience on DolRise. These systems are designed with strict safeguards and do not perform permanent emotional profiling, psychological assessment, or medical inference. Any emotion-related signals are processed with time-based limitations and are not retained as long-term personal records.

Where users participate in monetisation features, withdrawals, or other regulated activities, DolRise may collect identity verification information and financial details as required by law. Such data is processed using encryption and access controls and is retained only for the duration required to meet legal, regulatory, and fraud prevention obligations.

This Nigeria Privacy Policy should be read together with the DolRise Global Privacy Policy. Where there is any inconsistency between this policy and the Global Privacy Policy, this Nigeria Privacy Policy shall prevail for users located in Nigeria, to the extent required by applicable law.

DolRise may update this policy from time to time to reflect changes in law, regulatory guidance, or platform operations. Users in Nigeria are encouraged to review this policy periodically to remain informed about how their personal data is protected.

Scope and Applicability

This Nigeria Privacy Policy applies to individuals who access or use DolRise services within the Federal Republic of Nigeria, or who are otherwise subject to the Nigeria Data Protection Act (NDPA) 2023 as data subjects.

This policy governs the collection, use, storage, and protection of personal data processed by DolRise in connection with the operation of its platform, including but not limited to account registration, content interaction, platform security, and monetisation-related activities.

This Nigeria Privacy Policy operates alongside the DolRise Global Privacy Policy. The Global Privacy Policy sets out general data protection principles applicable to all users worldwide. Where there is any conflict or inconsistency between this Nigeria Privacy Policy and the Global Privacy Policy, this Nigeria Privacy Policy shall prevail for users located in Nigeria, to the extent required by applicable law.

This policy does not apply to information that does not qualify as personal data under Nigerian law, including anonymised or aggregated data that cannot reasonably be linked to an identifiable individual.

In circumstances where DolRise processes personal data solely on behalf of a third party as a service provider, such processing shall be governed by the relevant contractual arrangements and applicable legal obligations.

This policy takes effect from the Effective Date stated above and remains applicable for as long as a user accesses or uses DolRise services from Nigeria, subject to any updates made in accordance with applicable law.

Types of Personal Data Collected

DolRise collects personal data only to the extent necessary to operate its services, maintain platform security, comply with legal obligations, and provide lawful monetisation features. The categories of personal data described below apply to users located in Nigeria, in accordance with the Nigeria Data Protection Act (NDPA) 2023.

Account information. When a user creates an account, DolRise may collect basic account details such as a username, email address, and other contact information required to verify and secure the account.

Usage and interaction data. DolRise may collect information related to how users interact with the platform, including content views, “feel” and “reflect” interactions, session activity, and general usage patterns. This information is used to improve service quality and platform reliability.

Security and technical data. To protect users and the integrity of the platform, DolRise may process technical information such as log data, device-related signals, and other indicators used for fraud prevention, abuse detection, and system security.

Identity verification and financial data. Where users engage in monetisation, withdrawals, or other regulated activities, DolRise may collect government-issued identification information and financial details as required by applicable law. Such data is processed using encryption and strict access controls and is retained only for legally required periods.

Automated and algorithmic processing data.Certain data may be processed through automated systems to enhance user experience. DolRise does not retain emotional signals or inference data as permanent records, does not perform psychological or medical assessments, and applies time-based limitations to any emotion-related processing.

Data not collected. DolRise does not collect personal data that is unnecessary for platform operations, and does not collect personal information for the purpose of selling or trading user data.

Purpose of Processing

DolRise processes personal data of users located in Nigeria only for specific, explicit, and legitimate purposes, in accordance with the Nigeria Data Protection Act (NDPA) 2023. Personal data is not processed in a manner incompatible with these stated purposes.

Provision of platform services. Personal data is processed to create and manage user accounts, enable access to platform features, and ensure the reliable operation of DolRise services.

Service improvement and platform reliability.Certain data may be processed to understand platform usage, identify technical issues, and improve functionality and user experience, without creating permanent behavioural or emotional profiles.

Security, safety, and fraud prevention.DolRise processes personal data to protect users and the platform, detect unauthorised activity, prevent fraud, and maintain the integrity of its systems.

Legal and regulatory compliance. In some circumstances, DolRise processes personal data to comply with applicable laws, regulations, and lawful requests from public authorities, including obligations related to financial regulation and anti-fraud requirements.

Monetisation and payments. Where users participate in monetisation, withdrawals, or payment-related features, personal data may be processed to verify identity, process transactions, and comply with financial and regulatory obligations.

User support and communications. Personal data may be processed to respond to user enquiries, provide customer support, communicate important service-related information, and address security or account-related matters.

DolRise does not process personal data for the purpose of selling personal information, engaging in deceptive practices, or conducting psychological or medical assessments. All data processing activities are limited to what is reasonably necessary to achieve the purposes described above.

Legal Basis for Processing

DolRise processes personal data of users located in Nigeria only where a valid legal basis exists, in accordance with the Nigeria Data Protection Act (NDPA) 2023. Each category of personal data processed by DolRise is linked to a specific and lawful basis recognised under applicable Nigerian law.

Consent. In certain circumstances, DolRise processes personal data based on the user’s freely given, specific, informed, and unambiguous consent. Where consent is relied upon, users have the right to withdraw such consent at any time, subject to legal or contractual limitations.

Performance of a contract. Personal data may be processed where necessary to perform a contract to which the user is a party, or to take steps at the user’s request prior to entering into such a contract. This includes the provision of core platform services and account-related functionality.

Legal obligation. DolRise may process personal data where required to comply with applicable legal and regulatory obligations, including financial, tax, anti-fraud, and law enforcement requirements under Nigerian law.

Legitimate interests. In limited circumstances, DolRise may process personal data where necessary for its legitimate interests, such as maintaining platform security, preventing misuse, and improving service reliability, provided that such interests do not override the fundamental rights and freedoms of the user.

DolRise does not rely on a legal basis to process personal data for the purpose of selling personal information, engaging in deceptive practices, or conducting psychological or medical assessments. All processing activities are proportionate, transparent, and limited to what is reasonably necessary.

Automated Processing & Emotional Safety

DolRise uses limited forms of automated processing to support platform functionality and improve user experience. Such processing is designed with a human-first approach and operates within the boundaries established by the Nigeria Data Protection Act (NDPA) 2023.

Automated systems on DolRise may be used to organise content, manage platform stability, and reduce exposure to overwhelming or harmful interactions. These systems are not designed to manipulate users, encourage excessive engagement, or exert psychological pressure.

DolRise does not engage in permanent emotional profiling, psychological assessment, or medical inference. Any emotion-related signals used by automated systems are processed on a temporary basis, are subject to time-based expiry, and are not retained as long-term personal records.

Automated processing on DolRise does not produce legal or similarly significant effects on users. Such systems are not used to deny access to services, make binding decisions, or restrict user rights without meaningful human oversight.

Where automated systems are used, users retain meaningful control over their experience. This may include the ability to adjust preferences, limit algorithmic influence, or engage with the platform in a neutral or non-personalised mode, where such options are available.

DolRise is not a medical or therapeutic service. Automated systems are not intended to diagnose, treat, or monitor mental health conditions. The purpose of emotional safety measures is to support a respectful and balanced digital environment, not to replace professional care or advice.

These safeguards are intended to ensure that automated processing remains proportionate, transparent, and aligned with user dignity, while respecting applicable Nigerian data protection laws.

Data Retention

DolRise retains personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, in accordance with the Nigeria Data Protection Act (NDPA) 2023. Personal data is not retained indefinitely and is subject to periodic review.

Account data. Personal data required to create and maintain a user account is retained for the duration of the account’s active status. Where an account is closed, such data is deleted or anonymised unless continued retention is required by law.

Identity verification and financial data.Where personal data is collected for identity verification, monetisation, withdrawals, or payment processing, such data is retained only for the period required by applicable financial, anti-fraud, or regulatory obligations. Once those obligations are satisfied, the data is securely deleted or rendered non-identifiable.

Security and operational logs. Certain technical or security-related information may be retained for a limited period to detect, prevent, or investigate fraud, misuse, or security incidents. Such information is reviewed regularly and deleted when no longer necessary.

Automated and emotion-related data. DolRise does not retain emotional signals or inference data as long-term personal records. Any such data is subject to time-based expiry and decay mechanisms designed to prevent persistent profiling.

Aggregated and de-identified data. DolRise may retain aggregated or de-identified information for analytical and service improvement purposes. This information cannot be used to identify individual users and is not treated as personal data under Nigerian law.

Retention practices are reviewed periodically to ensure that personal data is not kept longer than necessary, and to maintain compliance with applicable Nigerian data protection requirements.

Data Sharing & Third Parties

DolRise limits the sharing of personal data to what is necessary and lawful, in accordance with the Nigeria Data Protection Act (NDPA) 2023. Personal data is not sold and is not shared for commercial exploitation.

Service providers. DolRise may share limited personal data with trusted service providers who assist in the operation of the platform, including payment processing, security services, technical infrastructure, and data storage. Such providers are bound by contractual obligations to process data only on DolRise’s instructions and to apply appropriate security safeguards.

Legal and regulatory requirements. Personal data may be disclosed where required to comply with applicable laws, lawful requests from public authorities, or valid court orders. In such cases, disclosure is limited to what is legally required.

Financial services and monetisation. Where users engage in monetisation, withdrawals, or payment-related features, personal data may be shared with financial institutions or payment processors solely for the purpose of completing transactions, preventing fraud, and complying with regulatory obligations.

Business changes. In the event of a merger, acquisition, restructuring, or similar business transaction, personal data may be transferred as part of that transaction. Any such transfer remains subject to this Privacy Policy and applicable data protection laws.

DolRise does not share personal data for behavioural advertising, unauthorised tracking, or practices that undermine user privacy. All data sharing arrangements are periodically reviewed to ensure compliance with Nigerian data protection requirements.

User Rights Under the NDPA

Under the Nigeria Data Protection Act (NDPA) 2023, users located in Nigeria have specific rights in relation to the processing of their personal data. DolRise respects these rights and provides mechanisms for users to exercise them in a transparent and fair manner.

Right to be informed. Users have the right to receive clear information about the collection and use of their personal data, including the purposes of processing, the types of data involved, and applicable retention periods.

Right of access. Users may request confirmation as to whether DolRise processes their personal data and, where applicable, obtain a copy of such data together with relevant information about its use.

Right to rectification. Users have the right to request the correction or completion of inaccurate or incomplete personal data held by DolRise.

Right to erasure. In certain circumstances, users may request the deletion of their personal data, particularly where the data is no longer necessary for the purposes for which it was collected or where consent has been withdrawn. This right may be limited where retention is required by law.

Right to restrict processing. Users may request a temporary restriction of processing, for example where the accuracy or lawfulness of the data is being contested.

Right to data portability. Where applicable, users may request to receive their personal data in a structured, commonly used, and machine-readable format, or to have it transmitted to another data controller.

Right to object. Users have the right to object to certain types of processing, particularly where processing is based on legitimate interests, subject to applicable legal limitations.

Automated processing. Users have rights in relation to automated processing, including the right to seek clarification and to challenge processing that may significantly affect them, where such rights are provided under applicable law.

Requests to exercise these rights may be submitted using the contact details provided in this Privacy Policy. DolRise will respond within the timeframes required under Nigerian data protection law.

International Data Transfers

DolRise operates on a global infrastructure and, in certain circumstances, personal data of users located in Nigeria may be transferred to, processed in, or accessed from countries outside Nigeria. Such transfers are conducted in accordance with the Nigeria Data Protection Act (NDPA) 2023.

Personal data is transferred internationally only where necessary for legitimate operational purposes, including the provision of technical infrastructure, security services, payment processing, or compliance with legal obligations.

Prior to any international transfer, DolRise takes reasonable steps to ensure that the recipient country, organisation, or service provider offers an adequate level of data protection. Where required, appropriate contractual safeguards and data protection commitments are put in place.

DolRise applies technical and organisational security measures, such as encryption and access controls, to protect personal data during international transfers and subsequent processing.

DolRise does not transfer personal data to jurisdictions that lack adequate data protection safeguards without implementing additional measures designed to protect user privacy and data security.

Users located in Nigeria have the right to request further information regarding international data transfers and the safeguards applied, in accordance with applicable Nigerian data protection law.

Data Security

DolRise treats the security of personal data as a core obligation and applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, misuse, or disclosure, in accordance with the Nigeria Data Protection Act (NDPA) 2023.

Technical safeguards. DolRise implements industry-standard technical measures, including encryption of data in transit and at rest, access control mechanisms, monitoring systems, and protections against unauthorised system access or cyber threats.

Organisational safeguards. Access to personal data is limited to authorised personnel who require such access for legitimate business purposes. Employees and contractors receive training on data protection and confidentiality obligations and are subject to internal security policies.

Protection of sensitive data. Where DolRise processes sensitive categories of data, including identity verification or financial information, enhanced security measures are applied, such as stricter access controls and additional encryption safeguards.

Incident management. DolRise maintains procedures for identifying, assessing, and responding to data security incidents. Where a personal data breach occurs that poses a risk to users, DolRise will take appropriate remedial action and provide notifications as required under applicable Nigerian law.

While no system can guarantee absolute security, DolRise continuously reviews and improves its security practices to reduce risks and maintain the integrity and confidentiality of personal data.

Children’s Privacy

DolRise recognises the importance of protecting the privacy and personal data of children. In accordance with the Nigeria Data Protection Act (NDPA) 2023, special care is taken when handling any personal data relating to children.

DolRise services are primarily intended for adult users. The platform does not knowingly collect personal data from children without appropriate legal authorisation or parental consent, where such consent is required by law.

If DolRise becomes aware that personal data of a child has been collected without the required consent or legal basis, such data will be promptly deleted, and appropriate steps will be taken to prevent further processing.

Where personal data of children is processed in compliance with applicable legal requirements, DolRise applies enhanced security measures, including restricted access and additional safeguards, to protect such data from misuse or unauthorised disclosure.

Parents or legal guardians have the right to request information regarding the personal data of their children and may request correction or deletion of such data, subject to applicable legal limitations.

DolRise does not use children’s personal data for advertising, behavioural profiling, or any form of commercial exploitation.

Updates & Changes

DolRise may update or revise this Privacy Policy from time to time to reflect changes in legal requirements, regulatory guidance, operational practices, or platform features, in accordance with the Nigeria Data Protection Act (NDPA) 2023.

Updates may include clarifications, additions, or modifications intended to improve transparency, strengthen data protection safeguards, or ensure continued compliance with applicable Nigerian law. Such updates are not intended to reduce user rights under this Privacy Policy.

Where material changes are made that affect how personal data is processed, DolRise will provide reasonable notice to users, including by publishing the updated Privacy Policy on the platform or through other appropriate communication channels.

Each version of this Privacy Policy will indicate the date on which it becomes effective. Continued use of DolRise services after the effective date of an updated policy constitutes acceptance of the revised terms, to the extent permitted by applicable law.

Users who do not agree with any updates to this Privacy Policy may discontinue use of the services or contact DolRise for further information regarding the changes.

Contact Information

DolRise is committed to transparency and accountability in the handling of personal data. Users located in Nigeria may contact DolRise with questions, concerns, or requests relating to this Privacy Policy or the processing of personal data.

At this time, DolRise does not maintain a dedicated data protection representative located in Nigeria. However, all privacy-related enquiries are handled promptly and in accordance with applicable Nigerian data protection laws.

Privacy contact email:
[email protected]

Requests submitted via this contact address may include, but are not limited to, enquiries about data processing practices, requests to exercise data subject rights under the Nigeria Data Protection Act (NDPA) 2023, or questions regarding this Privacy Policy.

DolRise will review and respond to all valid requests within reasonable timeframes and in accordance with applicable legal requirements.