1. Introduction
Spaccy ("Spaccy", "we", "us", or "our") respects your privacy and is committed to protecting your personal information.
This Privacy Policy explains how we collect, use, store, protect and share personal information when you use the Spaccy website, mobile application, marketplace, event management tools, Olivia AI and other services provided by Spaccy.
This Policy applies to customers, vendors, venue owners, event professionals and other users of the Spaccy platform.
We process personal information in accordance with applicable data protection laws, including the Nigeria Data Protection Act 2023 (NDPA) and other applicable requirements.
By using Spaccy, you acknowledge this Privacy Policy. Where applicable law requires your consent for a particular type of processing, we will request that consent separately.
2. Information We Collect
We collect information that you provide directly, information generated when you use Spaccy and, where necessary, information received from third parties.
2.1 Information You Provide
Account and Profile Information
When you create an account, we may collect:
- Full name
- Email address
- Phone number
- Password and login credentials
- Profile photograph
- Location
- Account preferences
- Other information you choose to provide
Customer and Event Information
When you use Spaccy to plan or book an event, we may collect information such as:
- Event type
- Event date
- Event location
- Number of guests
- Event budget
- Colours and style preferences
- Dress code
- Indoor or outdoor requirements
- Event requirements and preferences
- Booking information
- Information shared with vendors or venues
- Other information you provide while planning your event
This information may be used to provide Spaccy's planning tools and Olivia AI.
Vendor and Venue Information
If you register as a vendor or venue owner, we may collect:
- Business or trading name
- Business address
- Contact information
- Business registration information
- Business category
- Services offered
- Pricing information
- Business description
- Portfolio photographs and videos
- Availability information
- Bank account information required for payments
- Verification information where required
- Other information necessary to operate your business account
Communications
We may collect and retain communications made through Spaccy, including:
- Messages between customers and service providers
- Enquiries
- Customer support conversations
- Complaints
- Reviews
- Other communications relating to your use of Spaccy
3. Payment Information
Payments made through Spaccy are processed using Flutterwave, our payment service provider.
When you make or receive a payment through Spaccy, relevant transaction information may be processed by Flutterwave and other financial institutions or payment partners involved in completing the transaction.
This may include information such as:
- Name
- Email address
- Phone number
- Transaction amount
- Transaction reference
- Payment status
- Payment method
- Bank or account information where required
- Other information necessary to process or verify a transaction
Payment card and other sensitive payment credentials may be collected directly by Flutterwave or the relevant payment provider rather than being stored directly by Spaccy.
Flutterwave processes personal and financial information in accordance with its own privacy practices and applicable financial and data protection requirements.
For more information about how Flutterwave handles personal information, please review the Flutterwave Privacy Notice.
4. Information We Collect Automatically
When you use Spaccy, we may automatically collect certain technical and usage information.
This may include:
- IP address
- Device type
- Operating system
- Browser type
- App version
- Device identifiers
- Pages and features visited
- Searches and interactions
- Date and time of activity
- Session information
- Approximate location information
- Diagnostic information
- Performance information
We use this information to operate, secure, monitor and improve Spaccy.
5. Cookies and Similar Technologies
Spaccy uses cookies and similar technologies to:
- Keep you signed in
- Remember your preferences
- Maintain account and platform security
- Improve website and application performance
- Understand how users interact with Spaccy
- Analyse usage
- Measure product and marketing performance
For more information, please read our Cookie Policy.
6. Information We Receive from Third Parties
We may receive information from third parties where necessary to provide or improve our services.
These third parties may include:
- Payment providers
- Banks and financial institutions
- Identity or business verification providers
- Analytics providers
- Technology providers
- Cloud and hosting providers
- Communication providers
- Fraud prevention and security providers
We may also receive information where you choose to connect Spaccy with another service.
7. How We Use Your Information
We use personal information for the following purposes.
7.1 Providing Spaccy Services
We use your information to:
- Create and manage your account
- Provide access to Spaccy
- Connect customers with vendors and venues
- Facilitate bookings
- Process payments
- Manage events
- Enable communication between users
- Provide customer support
- Provide event planning and management tools
7.2 Olivia AI
Spaccy's AI assistant, Olivia, uses information you provide to help create personalised event planning recommendations.
Depending on the information you provide, Olivia may help generate:
- Event concepts
- Planning checklists
- Event timelines
- Budget guidance
- Recommendations
- Vendor suggestions
- Other event planning information
Olivia's recommendations are generated from the information available to the system and may not always be accurate, complete or current.
You should verify important information, including prices, availability, vendor information and other important decisions, before relying on an AI-generated recommendation.
7.3 Improving Spaccy
We may analyse information about how users interact with Spaccy to:
- Improve existing features
- Develop new products and services
- Identify technical problems
- Improve platform performance
- Understand user needs
- Improve the overall user experience
Where possible, we may use aggregated or anonymised information for these purposes.
7.4 Communications and Marketing
We may use your information to send:
- Account notifications
- Booking updates
- Payment notifications
- Security alerts
- Service announcements
- Customer support communications
- Newsletters
- Promotional offers
- Marketing communications
You can unsubscribe from marketing communications at any time.
You will continue to receive essential communications necessary to operate your account or bookings.
7.5 Security and Fraud Prevention
We may use information to:
- Protect accounts
- Detect suspicious activity
- Prevent fraud
- Investigate misuse
- Protect customers and service providers
- Maintain the security and integrity of Spaccy
7.6 Legal and Regulatory Requirements
We may process personal information where necessary to:
- Comply with applicable laws
- Meet regulatory requirements
- Respond to lawful requests
- Prevent or investigate fraud
- Establish, exercise or defend legal claims
8. Legal Basis for Processing
Depending on the circumstances, Spaccy may process your personal information because:
- It is necessary to provide services you have requested.
- It is necessary to perform a contract with you.
- You have given consent.
- It is necessary for our legitimate business interests.
- It is necessary to protect the security of our platform or users.
- We are required to process the information by law.
Where we rely on your consent, you may withdraw your consent where permitted by law.
Withdrawing consent does not affect processing that took place before your consent was withdrawn.
9. How We Share Your Information
We do not sell your personal information.
We may share information where reasonably necessary to operate Spaccy and provide our services.
9.1 With Customers, Vendors and Venue Owners
When necessary to complete a booking or provide an event service, relevant information may be shared with the other party.
For example, a vendor may receive information necessary to fulfil a customer's booking.
We aim to share only information reasonably necessary for the relevant service.
9.2 With Payment and Financial Service Providers
We share relevant information with Flutterwave and other financial institutions or payment partners where necessary to process, verify, settle or manage payments and transactions.
9.3 With Technology and Service Providers
We may share information with trusted companies that help us operate Spaccy, including:
- Cloud and hosting providers
- Analytics providers
- Customer support providers
- Communication providers
- Security providers
- Fraud prevention providers
- Technology providers
These providers may process information on our behalf and are expected to apply appropriate safeguards.
9.4 Legal and Regulatory Authorities
We may disclose personal information where required or permitted by law, including in response to:
- Court orders
- Law enforcement requests
- Regulatory requirements
- Legal proceedings
- Other lawful requests
9.5 Business Transfers
If Spaccy is involved in a merger, acquisition, investment, restructuring, sale of assets or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.
10. International Data Transfers
Some of Spaccy's technology, payment or service providers may operate outside Nigeria.
As a result, your personal information may be processed or stored in another country.
Where personal information is transferred outside Nigeria, Spaccy will take reasonable steps to ensure that the information receives appropriate protection in accordance with applicable data protection requirements.
11. Data Security
We take reasonable measures to protect your personal information against:
- Unauthorised access
- Loss
- Misuse
- Alteration
- Unauthorised disclosure
- Destruction
Our security measures may include appropriate technical, organisational and administrative safeguards.
However, no internet-based platform or electronic transmission can be guaranteed to be completely secure.
If Spaccy becomes aware of a personal data breach that requires notification under applicable law, we will take appropriate steps to investigate, contain and notify the relevant parties as required.
12. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.
The length of time we retain information depends on factors including:
- The type of information
- Why we collected it
- Whether you continue to use Spaccy
- Legal and regulatory requirements
- Accounting and tax requirements
- Fraud prevention
- Dispute resolution
- Legitimate business requirements
When personal information is no longer required, we may securely delete, anonymise or otherwise dispose of it in accordance with applicable law.
13. Your Privacy Rights
Depending on applicable law, you may have rights relating to your personal information.
These may include:
Right to Be Informed
You have the right to understand how your personal information is collected and used.
Right of Access
You may request information about the personal information we hold about you.
Right to Correction
You may ask us to correct inaccurate or incomplete personal information.
Right to Deletion
You may request deletion of your personal information where legally permitted.
Right to Restrict Processing
You may request that we limit how your personal information is processed in certain circumstances.
Right to Object
You may object to certain types of processing, including direct marketing where applicable.
Right to Data Portability
Where applicable, you may request your personal information in a structured and commonly used format.
Right to Withdraw Consent
Where we rely on consent to process your information, you may withdraw that consent.
Right to Complain
Where applicable, you may lodge a complaint with the relevant data protection authority if you believe your privacy rights have been infringed.
These rights may be subject to legal limitations or exceptions.
14. How to Exercise Your Rights
To make a privacy request, contact our Data Protection Officer using the contact details below.
We may ask you to provide reasonable information to verify your identity before responding to a request.
This is designed to protect your information and prevent unauthorised access.
We will respond to valid requests within the timeframe required by applicable law.
15. Children's Privacy
Spaccy is intended for users aged 18 and above.
We do not knowingly collect personal information from children under 18 for the purpose of providing our services.
If we become aware that we have collected personal information from a child contrary to applicable law, we will take reasonable steps to delete the information.
16. Third-Party Websites and Services
Spaccy may contain links to third-party websites, applications or services.
These third parties operate independently from Spaccy and may have their own privacy policies and practices.
We are not responsible for the privacy practices of third-party services.
We encourage you to review their privacy policies before providing personal information.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
- Changes to our services
- Changes in technology
- Changes in applicable laws
- Changes in how we process personal information
When we make significant changes, we will update the Policy and its Effective Date and may provide additional notice where required.
We encourage you to review this Privacy Policy periodically.
18. Contact Us
If you have any questions, concerns or requests relating to this Privacy Policy or your personal information, please contact:
