Privacy Notice

This Privacy Notice for ATOD Tech, a company operating in Lagos, Nigeria ("we", "us" or "our"), explains how and why we collect, store, use and share ("process") your personal information when you use our services ("Services"), including when you:

• download and use our mobile application, InstantLinkUp, or any other application of ours that links to this Privacy Notice;
• visit our website at https://instantlinkup.com or any website of ours that links to this Privacy Notice; or
• contact us, or take part in events and other activities we run.

Questions or concerns? Reading this notice will help you understand your privacy rights and choices. We decide how your personal information is processed, so we are the data controller. If you do not agree with how we handle your information, please do not use the Services. If you have any questions, email us at privacy@instantlinkup.com.

Summary of Key Points

What personal information do we process? The details you give us when you sign up and build your profile, the content you share with other members, your location while you use the app, and, if you choose to verify your identity, your identity documents and a selfie. See section 1.

Do we process sensitive personal information? Yes, but only if you choose to verify your identity. Verification uses a government issued ID, a second ID, proof of address and a selfie. We only process these with your explicit consent. See section 1.

Do we collect information from third parties? Only subscription confirmations from Google Play or the App Store, passed to us by RevenueCat. We do not buy data about you from data brokers or marketing partners.

How do we process your information? To run your account, to help you meet people and events near you, to keep members safe, to take payments, to support you, and to comply with the law. See section 2.

Do we sell your information or use it for advertising? No. We do not sell personal information, we do not show third party advertising today, and we do not track you across other apps or websites. If we start showing ads on the free plan, we will update this notice first. See section 6.

Who do we share personal information with? Other members see your profile. The service providers that host and run the Services process data on our behalf, and some of them are outside Nigeria. See section 3.

How long do we keep it? For as long as your account is open. We delete or anonymise it within three (3) months after your account is closed, except where the law requires us to keep it for longer. See section 7.

What are your rights? You can access, correct, export and delete your information, withdraw consent, and complain to the Nigeria Data Protection Commission. See section 10.

1. What Information Do We Collect?

In short: we collect what you give us, what the app needs to work, and a small amount of technical information.

Information you give us

• Account details: your full name, email address, phone number, date of birth and a password. We store the password only in a scrambled (hashed) form that cannot be read back.
• Profile: username, bio, category (such as Business or Friendship), occupation, hobbies and interests, and up to four profile photos.
• Location you set: the area you choose during onboarding or in your profile, used to show people and events near you.
• App security: a PIN, stored only in hashed form, and whether you have turned on Face ID or fingerprint unlock. Your face or fingerprint never leaves your phone and is never sent to us.
• Identity verification (optional): if you choose to get the verified badge, we collect a government issued national ID, a second ID (passport or driver's licence), a proof of address document such as a utility bill, your home address, and a selfie. Our staff compare the selfie with your ID photo by eye. We do not create facial templates or use automated face recognition.
• Next of kin (optional, part of verification): the name, relationship, phone number, email address and address of a person you nominate.
• Safety circle (optional): the names, email addresses and phone numbers of trusted contacts you add, so we can alert them if something goes wrong during a meetup.
• What you share with other members: chat messages and photos sent in chat, community posts, comments, likes and photos, events you create, invitations, and the meetups you arrange (times, venue and status).
• Connections and safety actions: who you connect with, who you block, and reports you make about other members.
• Support messages: what you send us through Help & Support.
• Referrals: your referral code and who joined through it.
• Account deletion feedback (optional): the reason you give when deleting your account.

Information collected when you use the app

• Location while you use the app: your device location, only while the app is open, to show people and events near you. We show other members an approximate distance, never your exact position.
• Live location during a meetup: only while a meetup is in progress and you have turned on location sharing, and only while the app is open. It is shown to the member you are meeting and included in any safety alert. We keep only your most recent position.
• Device and sign in information: your IP address, your device and app version (as reported by your device), when you last signed in and when you were last active. We use this to keep your account secure and to show whether you are online.
• Push notifications: a push token for your device and its platform (iOS or Android), if you allow notifications.

We do not access your contacts, microphone, calendar, SMS messages or location while the app is closed.

Information from payments

If you buy LinkUp Plus, you pay Google (through Google Play) or Apple (through the App Store), and they process your payment details under their own privacy policies. We never see your card or bank details. RevenueCat, the service that tracks subscriptions for us, receives your member ID and the purchase from the store, and tells us which plan you bought, the price and currency, when it started, when it renews or ends, and the store's reference for it. RevenueCat also receives basic information about your device and app version.

Discovery preferences and visibility settings

If you save discovery filters, choose a place to preview before you travel, or change who can see you, we store those choices with your account so the app can apply them.

Sensitive personal information

Your government issued ID numbers and identity documents, and the selfie used to verify you, are sensitive personal information. We only collect them if you choose to verify your identity, and only with your explicit consent, which you give before you start verification. You can use InstantLinkUp without verifying, although some features may require a verified account.

Information about other people

When you add next of kin or safety circle contacts, you give us another person's details. Please only add someone who has agreed to it. We use their details only to contact them about your safety, never for marketing.

2. How Do We Process Your Information?

In short: to provide the Services, to keep members safe, and to meet our legal obligations.

We do not send marketing emails. If we start, we will ask for your consent first and you will be able to opt out at any time.

3. When and with Whom Do We Share Your Personal Information?

In short: with the service providers that run the Services for us, with other members as described in section 4, and where the law requires it. We never sell your information.

Service providers

These companies process personal information on our behalf, under contracts that require them to protect it and to use it only to provide their service to us.

We also show public events published on Eventbrite. We do not send Eventbrite any information about you.

Other situations

• Safety alerts: if you trigger a safety alert during a meetup, we email your safety circle contacts with the meetup details and your last known location.
• Legal requirements: we disclose information where the law requires it, for example in response to a valid court order or a request from law enforcement, or where it is needed to protect someone's life or safety.
• Business transfers: if we are involved in a merger, acquisition, financing or sale of all or part of our business, your information may be transferred as part of that deal. The new owner must continue to protect it as described in this notice.

International transfers

Some of our service providers store or process information outside Nigeria, including in the United States. We transfer personal information outside Nigeria only as the Nigeria Data Protection Act 2023 permits: where the recipient country or organisation ensures an adequate level of protection, where we have appropriate safeguards in place such as contractual clauses, or where another lawful basis for the transfer applies.

4. What Can Other Members See?

• Your profile: name, age, username, bio, category, occupation, hobbies, photos, whether you are verified, whether you are online, and your approximate distance from them.
• Your exact location: only the member you are meeting, only during a live meetup, and only if you turn sharing on.
• What you share: members you chat with see your messages, and members of a community see your posts and comments.

Members who block you, or whom you block, no longer see each other. A block hides your chat with that member rather than deleting it, so it can be reviewed if either of you reports the other, and it comes back if the block is lifted. Any meetup still planned between you is cancelled, and location sharing stops.

Our staff can see account details, identity verification documents, reports, support messages and meetup status, only when they need to for verification, safety, support or moderation. Staff do not read private chats, with one exception: when one member reports another, a member of our safety team can read the chat between those two members to review the report, including a chat hidden by a block. Each time this happens it is recorded.

5. What Is Our Stance on Third Party Websites?

The Services link to other websites, such as Eventbrite event pages. Those websites are not covered by this notice, and we are not responsible for how they handle your information. Please read their privacy notices.

6. Do We Use Cookies, Tracking or Automated Decisions?

The app does not use advertising, analytics or tracking tools today, and we do not track you across other companies' apps or websites. Our plans allow for ads on the free plan in future. Before any advertising provider receives information about you, we will update this notice, name the provider, and ask for your consent where the law requires it. Ads will never appear during safety checks or meetup verification. The app stores a sign in token on your device, in your phone's secure storage, to keep you signed in.

The people and events we suggest are ranked by your interests, category and distance. Messages and posts are checked automatically against a list of banned words and links, and a message that fails the check is not sent. We do not make decisions based solely on automated processing that have legal or similarly significant effects on you. Decisions to verify, suspend or disable an account are made by our staff.

7. How Long Do We Keep Your Information?

In short: while your account is open, and no longer than three (3) months after it is closed, unless the law requires otherwise.

• Account, profile, photos, messages, posts, connections and verification information: kept while your account is open, including chats hidden by a block. When you delete your account, it disappears from the Services immediately, and we delete or anonymise this information within three (3) months.
• Rejected identity verification submissions: deleted within three (3) months of the decision.
• Live meetup location: deleted when the meetup ends.
• Payment and transaction records: kept for as long as Nigerian tax and accounting law requires, and used only for that purpose.
• Reports and moderation records: kept for up to three (3) months after the reported account is closed, or longer if we need them for a legal claim or a law enforcement request.

Where information sits in backups and cannot be deleted at once, we keep it isolated and secure until the backup expires.

8. How Do We Keep Your Information Safe?

We use technical and organisational measures to protect your information. These include encrypting all traffic between the app and our servers, storing passwords and PINs only in hashed form, keeping identity documents in private storage that can only be opened through short lived links, and limiting staff access to what each role needs. No system is completely secure, so we cannot guarantee that unauthorised people will never get access. Please use a strong password and keep your phone's lock screen on.

9. Do We Collect Information from Minors?

The Services are only for adults aged 18 or older, and we check your date of birth when you sign up. We do not knowingly collect information from anyone under 18. If we learn that a user is under 18, we will close the account and delete their information. If you believe someone under 18 is using the Services, please contact us at privacy@instantlinkup.com.

10. What Are Your Privacy Rights?

You can:

• See and correct your information: most of it in the app, under Profile and Settings.
• Delete your account: in the app under Settings, Delete Account. Section 7 explains what happens next.
• Get a copy of your information, or ask us to restrict or stop processing it: email privacy@instantlinkup.com.
• Withdraw consent: for example, by turning off location sharing or notifications in your phone's settings, removing safety circle contacts, or asking us to delete your verification documents. Withdrawing consent does not affect processing that already took place, and some features may stop working.

We may need to confirm your identity before acting on a request. We reply within thirty (30) days.

11. Your Rights Under Nigerian Law

We process your personal information in accordance with the Nigeria Data Protection Act 2023 (NDPA) and the regulations, directives and guidance issued by the Nigeria Data Protection Commission (NDPC).

Under the NDPA, you have the right to:

• be informed about how we collect and use your personal information;
• request access to your personal information and a copy of it;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information, where permitted by law;
• request that we restrict the processing of your personal information;
• object to the processing of your personal information, including for direct marketing;
• receive your personal information in a structured, commonly used and machine readable format (data portability);
• withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal; and
• not be subject to a decision based solely on automated processing that produces legal or similarly significant effects on you.

Data breaches. If a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the NDPC within 72 hours of becoming aware of it. Where the breach is likely to result in a high risk to you, we will also notify you without undue delay.

Complaints. If you are not satisfied with how we handle your personal information, you can complain to the Nigeria Data Protection Commission (https://ndpc.gov.ng).

12. Do We Make Updates to This Notice?

We may update this notice from time to time. The date at the top shows when it last changed. If we make a material change, we will tell you in the app or by email before it takes effect.

13. How Can You Contact Us About This Notice?

Email privacy@instantlinkup.com, or write to:

ATOD Tech 3 Igbobi St, off Ait, Jibowu, Yaba, Lagos, Nigeria