Privacy Policy

MyCityApp respects your privacy and is committed to protecting your personal data. This privacy policy will inform you of how we look after your personal data when you use our mobile application (“App”) (regardless of where you are located) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. THIRD-PARTY PROCESSING
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. CHANGES TO PRIVACY POLICY
11. GLOSSARY

1. Important information and who we are.
Purpose of this privacy policy
This privacy policy aims to give you information on how MyCityApp collects and processes your personal data through your use of our App, including any data you may provide through our App when you use any of our services, and the steps you can take to protect your privacy. Our App is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Third-party links
This App may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices and procedures. When you leave our App, we encourage you to read the privacy policy of every website you visit through our App.

2. The information we collect about you.
Personal data means any information relating to an identified or identifiable natural person. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes name, username or similar identifier, title, date of birth, photograph/photo ID, gender.
• Contact Data includes residential/contact address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments to and from you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this App.
• Profile Data includes your username and password, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our App, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific feature on our App. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Neither do we collect any information about criminal convictions and offences.
If you fail to provide personal data Where we are required to collect personal data, or need it to provide our services to you, and you fail to provide that data when requested, we may be unable to provide the service to you.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your data by filling out forms or by corresponding with us by phone, email, or other available means. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our App;
• subscribe to our newsletters;
• request marketing materials or communication to be sent to you;
• make payments using our App;
• enter a competition, promotion, or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
• Third parties or publicly available sources. We may also receive and use personal data about you from various third parties e.g., analytics providers such as Google and public sources.
4. How we use your personal data
• We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
• To provide our product and services to you
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• When you give us consent.
• We will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to receive marketing materials at any time by contacting us.
Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Lawful basis
To provide products and services which you have requested, and to conduct business with you (for example, to register you as a new customer, to process your application, to manage your account, to tell you about important changes to our services, to process and to respond to your enquiries, complaints and issues) and to keep updated and bring together and improve records.
Performance of a contract with you For security, credit, identification and verification purposes. Comply with a legal obligation (e.g., compliance with our Anti-Money Laundering and Know Your Customer obligations).
To detect, investigate, prevent and prosecute criminal activity and to meet our regulatory, legal and compliance obligations (including performing regulatory and prudential compliance checks on an ongoing basis, account and transaction monitoring, checks for sanctions and politically exposed persons, and transaction and tax reporting. Also making disclosures to, co-operating with, and complying with requests from: public authorities, regulators, courts of law, tax authorities, governmental bodies or law enforcement agencies, and investigating and preventing fraud, terrorism and other crimes).
(a) Comply with a legal obligation
(b) Legitimate interests (ensuring effective compliance in all relevant jurisdictions, protecting our customers, maintaining a good relationship with law enforcement, regulators and other relevant authorities. Also, we have a legitimate interest in protecting our legal rights).
To improve customer service, and to decide if a product or service is suitable for your needs. Legitimate interests (we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively. Also, we have a legitimate interest in ensuring that we provide our customers with appropriate products and services, to ensure both appropriate risk management and good client relationship management.
To provide you with the appropriate level of service, to accommodate your specific individual needs and treat you fairly based on any vulnerability you may have, whether you have told us, or we believe it necessary to record, to improve customer service and ensure equality of treatment, protect vulnerable customers, or safeguard your economic wellbeing.
(a) Consent
(b) Public Interest
(c) Vital Interest
(d) Legitimate interests (we have a legitimate interest in providing quality customer service, as this allows us to maintain good client relationships and to deal with queries and complaints effectively).
To carry out operational and administrative functions (e.g. to maintain our own accounts and records, to operate information technology systems, to carry out billing-related and payments administration, to maintain stocks and shares registers).
(a) Comply with a legal obligation (to maintain certain statutory records)
(b) Legitimate interests (we have a legitimate interest in running our business efficiently).
To share relevant information in respect of a prospective sale of MyCityApp, or any of its subsidiaries, or any part of its or their business. (a) Comply with a legal obligation
(b) Legitimate interests (we have a legitimate interest in complying with due diligence requirements and being efficient in how we run the business).
To manage, support and provide training to our staff. Legitimate interests (we have a legitimate interest in managing, supporting and providing training to our staff).
Marketing: To tell you about other companies’ products, services and facilities that may interest you (by email, phone or text, in accordance with your preferences). (a) Consent
(b) Legitimate interests (we have a legitimate interest in making our customers aware of our other services and offerings).
We may share some personal data (for example, your email address), in a secure format, with our advertising partners and social media companies, so that they can display the most relevant messages to you and others about our products and services. This includes instructing these companies not to show adverts to our existing customers. If you do not want us to share your personal data with our advertising partners or social media companies for this purpose, you can tell us not to.
Legitimate interests (it is in our legitimate interests to give you information about our products and services that you or others may be interested in).
To evaluate the effectiveness of marketing and for research, training and statistical analysis with the aim of improving services. Legitimate interests (we consider that we have a legitimate interest in improving our products, services and operations).
To help us to improve our products, services and operations, including market research, analysis of customer preferences, transactions and market trends, evaluating proposed products, testing new systems and upgrading existing systems. Legitimate interests (we consider that we have a legitimate interest in improving our products, services and operations).
To manage our business and to protect and enforce our rights, including assessing, monitoring and managing financial, reputational and other risk, conducting audits, liaising with regulators and law enforcement, and to establish, enforce and defend against legal claims).
(a) Comply with a legal obligation
(b) Legitimate interests (we consider that we have a legitimate interest in prudently managing our business and in protecting and enforcing our rights).
To be able to work with other companies that provide services to us and our customers. Performance of a contract with you Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right to revoke your consent to such uses at any time by contacting us or adjusting your preferences through our communication channels. We are committed to respecting your choices and ensuring that your data is handled in accordance with your preferences.
Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or we have provided products or services to you and you have not opted out of receiving marketing communications.
Third-party marketing We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out You can ask us or third parties to stop sending you marketing messages at any time by logging into the App and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

COOKIES
The App may use cookies to enhance user experience, analyze app performance and provide tailored features. This enables the application to store information about your preferences or device usage and ensure seamless app functionality. You can manage or disable this tracking technology through your device settings or within the app settings. Note that disabling these features may impact your ability to access certain functionalities of the App. For more information about the cookies we use, please see Cookies Policy .

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Third-Party Processing
We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.
• Service providers acting as processors based in Nigeria who provide various services on the App.
• Regulators and other authorities based in Nigeria who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers We do not transfer your personal data outside of Nigeria.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How long will we use your personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
You have rights under data protection laws in relation to your personal data. You may:
• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data
• Withdraw consent
• Lodge a complaint with the relevant authority
If you wish to exercise any of the rights set out above, except the right to lodge a complaint with the relevant authority, please contact our Data Protection Officer: [provide data protection officer’s contact details] 10. Changes to the Privacy Policy
Our Privacy Policy may be updated from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice. We will also keep prior versions of this Privacy Policy in an archive for your review.
This version was last updated on February 29, 2025.
11. Glossary
LAWFUL PROCESSING
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.