Last updated: October 2026
1. Who we are
[Company Legal Name] ("we") is the controller of personal data processed through this Platform. Contact: supports@springhubprogramtest.com.ng. Registered address: [Registered Address].
2. Data we collect
Depending on how you use the Platform we collect:
- Account data: name, email address and a securely hashed password.
- Identity (KYC) data: date of birth, address, ID type and number, and uploaded identity documents, where verification is required.
- Transaction data: deposits, withdrawals, orders, holdings and ledger history.
- Technical data: IP address, browser and device details, and security logs such as sign-in events.
- Communications: messages you send through contact forms and newsletter subscriptions.
3. Why we use it (lawful bases)
- To create and run your account and provide the services (contract).
- To verify identity and meet anti-money-laundering and other legal duties (legal obligation).
- To secure the Platform, prevent fraud and enforce our terms (legitimate interests).
- To send marketing emails only where you have opted in (consent). You can unsubscribe at any time.
4. How we protect it
Passwords are hashed and never stored in plain text. Identity numbers are encrypted in the database. Identity documents are stored outside the public web folder and are only available to authorised staff. We use HTTPS, access controls, rate limiting and audit logging. No system is perfectly secure, and we will notify you and the relevant authority of a breach where the law requires it.
5. Sharing
We do not sell personal data. We share it only with service providers who help us run the Platform (for example hosting, email delivery and market-data providers), with regulators or law enforcement where legally required, and in a business transfer where the law allows. Service providers act on our instructions.
6. Retention
We keep data only as long as needed for the purposes above and to meet legal record-keeping requirements. Identity and transaction records may be retained for a period required by law after an account is closed. [State your retention periods.]
7. Your rights
Subject to applicable law (including the Nigeria Data Protection Act and, where relevant, the GDPR) you may request access, correction, deletion, restriction or portability of your data, and object to certain processing. You may withdraw consent at any time. To exercise these rights, contact us at supports@springhubprogramtest.com.ng. You may also complain to your data protection authority.
8. Cookies
We use essential cookies to keep you signed in and protect forms from cross-site request forgery. We do not use advertising cookies. If this changes we will update this policy and ask for consent where required.
9. International transfers and changes
Where data is processed outside your country we use appropriate safeguards required by law. We may update this policy and will post the new version here with a new date.