Privacy Policy - Domak Investment Platform (DIP)

1. Introduction

Welcome to the Domak Investment Platform ("DIP", "the App", "we", "us", "our"). This platform is owned and operated by Domak Group International. We are committed to protecting your privacy and ensuring your personal information is handled responsibly and transparently.

This Privacy Policy outlines how we collect, use, protect, and share your data when you use our mobile applications and related services (collectively, the "Services").

This policy is designed to comply with applicable data protection laws, including the Nigeria Data Protection Act (NDPA) 2023, and incorporates principles from global best practices like the General Data Protection Regulation (GDPR).

2. Definitions

Key terms used in this policy are defined as follows:

Personal Data: Any information relating to an identified or identifiable natural person (the "Data Subject").
Data Controller: The entity that determines the purposes and means of processing Personal Data. For our Services, Domak Group International is the Data Controller.
Data Processor: An entity that processes Personal Data on behalf of the Data Controller. We engage various Data Processors to provide our services.
Processing: Any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion.

3. Information We Collect

To provide and improve our Services, we collect the following types of information:

3.1. Information You Provide Directly

Account Information: When you register, we collect your full name, email address, phone number, and password.
Know Your Customer (KYC) Information: To comply with legal and regulatory requirements, we collect identity verification data, which may include government-issued ID numbers and proof of address.
Financial Information: Details related to your wallet top-ups, subscription payments, and other transactions. Please note, sensitive card details are handled directly by our payment processor, Paystack, and are not stored on our servers.
Communications: We collect information when you contact our support team or communicate with us through other channels.

3.2. Information We Collect Automatically

Usage Data: Information about how you interact with the App, such as features used, login times, and navigation patterns.
Device Information: Data about the device you use to access our Services, including IP address, operating system, and device type.
Location Data: With your explicit permission, we may collect your device's location to provide location-based services, such as for property mapping.

4. How We Use Your Information

We use the information we collect for the following purposes:

To Provide and Manage Services: To create and manage your account, process transactions, facilitate property investments, and operate the App.
To Comply with Legal Obligations: To perform identity verification (KYC) and meet anti-money laundering (AML) and other legal requirements.
For Communication: To send you transactional emails, SMS notifications, service updates, and marketing communications (where you have consented).
For Customer Support: To respond to your inquiries and resolve issues.
To Improve Our Services: To analyze user behavior, develop new features, and enhance the user experience.
To Ensure Security: To protect our platform from fraud, enforce our terms of service, and maintain the integrity of our systems.

5. How and Why We Share Your Information

We do not sell your personal data. We only share it in the following limited circumstances to operate our platform:

With Service Providers (Data Processors): We engage third-party companies to perform services on our behalf, such as cloud hosting, payment processing, and communications. We only share the information necessary for them to perform their services under strict data protection terms. A list of our key service providers is in the next section.
For Legal Reasons: We may disclose your information to law enforcement or government authorities if required by law, court order, or other legal processes.
In Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in control.

6. Our Third-Party Service Providers

To deliver our Services, we rely on the following key third-party service providers (Data Processors) who process data on our behalf:

Platform Development & Maintenance: Ephod Communications Ltd. (trading as EphodHost) is our core technology provider, responsible for developing, hosting, and maintaining the DIP application and its infrastructure.
Cloud & Hosting Infrastructure: Amazon Web Services (AWS) and Vultr for secure and scalable cloud hosting.
Payment Processing: Paystack for securely handling all financial transactions.
Transactional Emails: ZeptoMail for sending important account-related emails.
SMS Notifications: Africa's Talking for sending notifications via our integrated BulkSMS service.
Security & Performance: Cloudflare for web application firewall (WAF), DDoS protection, and content delivery.
AI & Specialized Computing: RunPod for hosting specialized AI models that power platform features.

We have data processing agreements with these providers to ensure they handle your data with a level of protection consistent with this policy and applicable laws.

7. Data Security

We are committed to protecting your information. We implement and maintain appropriate technical and organizational security measures to safeguard your Personal Data, including:

Encryption: Encrypting data both in transit (using TLS) and at rest.
Access Controls: Restricting access to Personal Data to authorized personnel with a legitimate business need.
Infrastructure Security: Utilizing secure cloud infrastructure with robust security features.
Regular Assessments: Conducting regular security assessments and vulnerability scanning.
Incident Response: Maintaining a plan to promptly respond to and manage any data breaches, including notifying you and relevant authorities as required by law.

8. Data Retention

We will retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, to provide you with our Services, to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer need your data, we will securely delete or anonymize it.

9. Your Rights and Choices

Under applicable data protection laws, you have the following rights regarding your Personal Data:

Right to Access: You can request a copy of the Personal Data we hold about you.
Right to Rectification: You can request that we correct any inaccurate or incomplete data.
Right to Erasure ('Right to be Forgotten'): You can request that we delete your Personal Data, subject to certain legal limitations.
Right to Data Portability: You can request that we provide your data in a structured, commonly used, and machine-readable format.
Right to Object: You can object to our processing of your data for marketing purposes.
Right to Withdraw Consent: Where we rely on your consent to process data, you can withdraw it at any time.

To exercise any of these rights, please contact us using the details in the "Contact Us" section below.

10. International Data Transfers

Our services are targeted at a global audience, and our technology infrastructure is international. Therefore, your Personal Data may be transferred to and processed in countries outside of Nigeria. When we do so, we ensure that appropriate safeguards are in place to protect your data in accordance with this policy and applicable laws.

11. Children's Privacy

Our Services are not intended for use by individuals under the age of 18. We do not knowingly collect Personal Data from children. If we become aware that we have inadvertently collected such information, we will take steps to delete it as soon as possible.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal or operational reasons. We will notify you of any material changes by posting the new policy in the App, on our website, or via email. We encourage you to review this policy periodically.