Legal · NDPR Compliant
Privacy Policy
Effective Date: March 27, 2026 · Nigeria Data Protection Regulation (NDPR) 2019
Gentility Tech Global Ltd ("we," "us," or "our"), operators of AfixHustlers, is committed to protecting your personal data in accordance with the Nigeria Data Protection Regulation (NDPR) 2019 and all applicable Nigerian laws. This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our Platform.
1Who We Are (Data Controller)
Data Controller: Gentility Tech Global Ltd
Platform: AfixHustlers (afixhustlers.com)
Address: No 7 Amalu Street Off Rehab Road, Emene, Enugu, Nigeria
Email: info@afixhustlers.com
2Data We Collect
We collect only data that is necessary to provide, improve, and secure our Platform. We collect the following categories of personal data:
Identity & Contact Data
- Full name or company name
- Email address
- Phone number
- National Identification Number (NIN) — collected only when you voluntarily submit for verification
- RC/BN Number (for registered businesses)
- Profile photo
Account & Profile Data
- Account type (Buyer or Hustler)
- Business type and category
- Location (state, city, or area)
- HustleScore and verification status
- Social media handles connected to the Platform
- Subscription plan and billing history
Transaction & Financial Data
- Payment references and transaction records
- Booking history and amounts
- Bank account details (for withdrawal — stored securely by our payment processor)
- Escrow records
Usage & Technical Data
- IP address and device information
- Browser type and operating system
- Pages visited and features used
- Log data and error reports
- Cookies and similar tracking technologies
User-Generated Content
- Listing titles, descriptions, and photos
- Reviews and ratings
- Messages and communications on the Platform
- AI-generated content created using HustleForge
3How We Use Your Data
We process your personal data on the following lawful bases under the NDPR:
Contract Performance: To create and manage your account, process payments, facilitate bookings, deliver escrow services, and provide subscription features you have paid for.
Legitimate Interests: To improve our Platform, detect and prevent fraud, ensure platform security, send service-related notifications, and build the HustleScore system.
Legal Obligation: To comply with Nigerian law, including NDPR compliance, tax obligations, anti-money laundering requirements, and responding to lawful government requests.
Consent: To send promotional communications and marketing messages. You may withdraw consent at any time by unsubscribing or contacting us.
4How We Share Your Data
We do not sell your personal data. We share your data only in the following circumstances:
Service Providers (Data Processors)
We engage trusted third-party service providers who process data on our behalf and are bound by confidentiality and data protection obligations:
| Provider | Purpose | Data Shared |
|---|---|---|
| FunZ | Payment processing | Email, payment amount, transaction reference |
| Bunce | SMS verification (OTP) | Phone number |
| Zoho Mail | Business communications | Email address, name |
| Cloud database providers | Secure data storage | All account data (encrypted) |
| Cloud hosting providers | Platform infrastructure | Usage and log data |
| AI service providers | HustleForge content generation | Business type, listing details (no personal identifiers) |
| Security & CDN providers | DDoS protection, performance | IP address, usage data |
Other Disclosures
- Between Users: Hustler profile information (name, location, business type, HustleScore) is visible to Buyers to facilitate transactions.
- Legal Requirements: We may disclose data to government authorities, law enforcement, or regulatory bodies when required by Nigerian law or court order.
- Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, with prior notice to you.
5National Identification Number (NIN)
⚠️ Special Category Data — Enhanced Protection
Your NIN is sensitive government-issued data. We collect it only when you voluntarily submit it for identity verification to improve your HustleScore. We commit to:
- Storing NIN data in encrypted form at rest and in transit.
- Never sharing your NIN with other users or third parties except where required by Nigerian law.
- Using NIN data solely for identity verification purposes on the Platform.
- Allowing you to request deletion of NIN data at any time, subject to legal retention obligations.
6Data Retention
We retain your personal data only for as long as necessary:
- Active accounts: For the duration of your account and for 2 years after account closure.
- Transaction records: For 7 years in compliance with Nigerian financial regulations.
- Verification data (NIN, RC/BN): For the duration of your account plus 2 years.
- Communications: For 2 years from the date of communication.
- Technical logs: For 12 months from collection.
After retention periods expire, data is securely deleted or anonymised.
7Your Rights Under NDPR
Under the Nigeria Data Protection Regulation (NDPR) 2019, you have the following rights regarding your personal data:
Right of Access
Request a copy of all personal data we hold about you.
Right to Rectification
Request correction of inaccurate or incomplete data.
Right to Erasure
Request deletion of your data, subject to legal retention requirements.
Right to Restrict Processing
Request that we limit how we use your data in certain circumstances.
Right to Data Portability
Receive your data in a structured, machine-readable format.
Right to Object
Object to processing based on legitimate interests or for marketing purposes.
Right to Withdraw Consent
Withdraw consent at any time where processing is based on consent.
Right to Lodge a Complaint
File a complaint with the National Information Technology Development Agency (NITDA).
To exercise any of these rights, contact us at info@afixhustlers.com. We will respond within 30 days as required by the NDPR.
8Cookies & Tracking
We use cookies and similar technologies to operate our Platform, remember your preferences, and analyse usage patterns. Types of cookies we use:
- Essential Cookies: Required for the Platform to function. Cannot be disabled.
- Functional Cookies: Remember your preferences and login state.
- Analytics Cookies: Help us understand how users interact with the Platform. This data is aggregated and anonymised.
You can control non-essential cookies through your browser settings. Disabling cookies may affect Platform functionality.
9Data Security
We implement appropriate technical and organisational measures to protect your data:
- All data transmitted between your device and our Platform is encrypted using TLS/HTTPS.
- Sensitive data including passwords and financial information is encrypted at rest.
- Access to personal data is restricted to authorised staff on a need-to-know basis.
- We conduct regular security assessments of our infrastructure.
- In the event of a data breach that poses a risk to your rights, we will notify you and NITDA within 72 hours as required by the NDPR.
10Children's Privacy
AfixHustlers is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a person under 18, we will delete it immediately. If you believe a minor has registered on our Platform, please contact us at info@afixhustlers.com.
11International Data Transfers
Some of our service providers operate servers outside Nigeria. Where we transfer your data internationally, we ensure appropriate safeguards are in place, including contractual data protection obligations consistent with NDPR requirements. We take steps to ensure your data receives the same level of protection regardless of where it is processed.
12Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. We will notify you of material changes via email or in-app notification at least 14 days before they take effect. The effective date at the top of this policy indicates when it was last updated. Continued use of the Platform after changes take effect constitutes acceptance.
13NITDA Complaint
If you are unsatisfied with how we handle your personal data, you have the right to lodge a complaint with the National Information Technology Development Agency (NITDA), the supervisory authority for data protection in Nigeria:
14Contact Our Data Protection Officer
For any privacy-related questions, data access requests, or concerns:
Data Protection Officer
Gentility Tech Global Ltd
No 7 Amalu Street Off Rehab Road, Emene, Enugu, Nigeria
Email: info@afixhustlers.com
Response time: Within 30 days as required by NDPR
© 2026 Gentility Tech Global Ltd. All rights reserved.