Privacy & Cookie Policy
In this document, “the Company” means Avvica Limited, the operator of the “Avvica” platform. “You” means the user. Effective date: 1 June 2026. This policy explains how the Company processes personal data of Sellers, Agents, Buyers and visitors, and how it uses cookies and similar technologies, consistent with the Nigeria Data Protection Act 2023 (“NDPA”).
1. Definitions
2. Who we are (Data Controller)
3. What we collect
4. How and why we use it (lawful bases)
| Why we process it (purpose) | Data used | NDPA lawful basis |
|---|---|---|
| Register you and create your account | Identity & contact details | Contract |
| Verify identity and business registration (KYC/KYB) | NIN/BVN, CAC/RC, ID documents | Legal obligation; legitimate interests (fraud prevention) |
| Vet and decide access | Identity, business, suitability data | Contract; legitimate interests (trust & safety) |
| Operate deals, attribution & the marketplace | Deal, listing, attribution, activity data | Contract |
| Process payments, settlement & installments | Payment, payout/bank details, transaction data | Contract; legal obligation |
| Apply, withhold and remit taxes (VAT/WHT) | Transaction & billing data | Legal obligation |
| Name-matched settlement checks | Bank-account name vs verified name | Legal obligation; legitimate interests (fraud prevention) |
| Confirm fulfilment & handle disputes | Messages, evidence, transaction data | Contract; legitimate interests (resolving disputes) |
| Send service & transactional messages | Contact details | Contract |
| Send marketing (where you opt in) | Contact details, preferences | Consent |
| Detect fraud, abuse & secure the Platform | Identity, device/log, activity data | Legal obligation; legitimate interests (security) |
| Comply with AML/CFT obligations | Identity, transaction, KYC data | Legal obligation |
| Improve and personalise the service | Usage, device, activity data | Legitimate interests (improving the service) |
| Respond to your data-rights requests | Contact + data in your request | Legal obligation |
| Respond to legal/law-enforcement requests | Whatever is lawfully required | Legal obligation |